Under what circumstances will a court uphold a warrantless arrest for possession of illegal drugs?

"Under Fourth Amendment theory, however, a reviewing court must make an objective evaluation of the facts and circumstances surrounding the arrest of an individual. See Terry v. Ohio, 392 U.S. 1 (88 S.Ct. 1868, 20 L.Ed.2d 889). Thus, if probable cause exists for the arrest of a person for a felony at the time of the arrest, the search incident to arrest will be upheld if reasonable in scope, although the officer did not accurately name the offense for which the arrest was made."

422 F.2d 660, 664 (8th Cir. 1970). See also Chaney v. Wainwright, 460 F.2d 1263 (5th Cir. 1972) (per curiam) (warrantless arrest for misdemeanor of damaging telephone equipment upheld because arresting officers had probable cause to arrest defendant for possession of burglar tools, a felony).