The following excerpt is from U.S. v. Barclift, 514 F.2d 1073 (9th Cir. 1975):
Both Zsido and the government base arguments on Chimel v. California, 395 U.S. 752, 89 S.Ct. 2034, 23 L.Ed.2d 685 (1969). Chimel authorizes police search of "the area into which an arrestee might reach in order to grab a weapon or evidentiary items," also phrased as "the area 'within his immediate control.' " 395 U.S. at 763, 89 S.Ct. at 2040.
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