In what circumstances will a search of a vehicle search result where the suspect is in police custody?

And in People v. Superior Court (Rhinehart) (1980) 114 Cal.App.3d 264, 170 Cal.Rptr. 639 a trunk search of a disabled vehicle was upheld where the suspects were in police custody.

Finally, in People v. Weston, supra, 114 Cal.App.3d 764, 170 Cal.Rptr. 856 a getaway car was searched four days after a jewelry store robbery. Jewelry was discovered in the passenger section of the vehicle in the recesses of the seats. The court held the fact that the defendant was in custody outside the car and a total of four officers were present did not vitiate the search.