Is there any requirement under federal search and seizure law that an auto search incident to an occupant's arrest must have some nexus between the vehicle and the crime for which the occupant was arrested?

There is no requirement under federal search and seizure law that an auto search incident to an occupant's arrest must have some nexus between the item to be seized and the crime for which the occupant was arrested. Indeed, one of the rationales for the search-incident-to-arrest exception is the safety of the arresting officer. This rationale is dependent upon the mere fact of a custodial arrest rather than the nature of the offense comprising the arrest. (See United States v. Robinson (1973) 414 U.S. 218, 94 S.Ct. 467, 38 L.Ed.2d 427.)

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