The following excerpt is from U.S. v. Vaughan, 718 F.2d 332 (9th Cir. 1983):
Two other interrelated theories have been advanced to justify the search. The government asserts that the search was proper incident to a lawful arrest or, under Terry v. Ohio, 392 U.S. 1, 88 S.Ct. 1868, 20 L.Ed.2d 889 to protect the officers.
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