The following excerpt is from U.S. v. Salazar, 805 F.2d 1394 (9th Cir. 1986):
It follows from this conclusion that the police may also examine the contents of any containers found within the passenger compartment, for if the passenger compartment is within reach of the arrestee, so also will containers in it be within his reach. Such a container may, of course, be searched whether it is open or closed, since the justification for the search is not that the arrestee has no privacy interest in the container, but that the lawful custodial arrest justifies the infringement of any privacy interest the arrestee may have.... "A custodial arrest of a suspect based on probable cause is a reasonable intrusion under the Fourth Amendment; that intrusion being lawful, a search incident to the arrest requires no additional justification." [United States v. Robinson, 414 U.S. 218, 235 [94 S.Ct. 467, 476, 38 L.Ed.2d 427] (1973) ]
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