California, United States of America
The following excerpt is from People v. Urruty, A152416 (Cal. App. 2018):
italics added.) A vehicle search incident to an arrest is limited to "the vehicle's passenger compartment and 'any containers therein.' " (People v. Nottoli (2011) 199 Cal.App.4th 531, 555-557; see also Gant, supra, 556 U.S. at pp. 343-344.)
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