What is the current state of the law in the context of a search warrant application?

^4. See United States v. Thompson, 29 F.3d 62, 65 (2d Cir. 1994) ("Consistent with the Fourth Amendment, law enforcement officials may open closed containers as part of an inventory search so long as they act in good faith pursuant to standardized criteria or established routine.") (internal quotation marks and ellipsis omitted).

^5. Cf. Arizona v. Gant, 556 U.S. 332, 346 (2009) (holding that law enforcement officers are permitted "to conduct a vehicle search when an arrestee is within reaching distance of the vehicle or it is reasonable to believe the vehicle contains evidence of the offense of arrest").