What is the test for obtaining a search warrant for a vehicle search in an incident to a recent occupant's arrest?

Appellant relies principally on Michigan v. Long (1983) 463 U.S. 1032 and Arizona v. Gant (2009) 129 S.Ct. 1710. The principle on which appellant relies is expressed most clearly in Arizona v. Gant: "Police may search a vehicle incident to a recent occupant's arrest only if the arrestee is within reaching distance of the passenger compartment at the time of the search or it is reasonable to believe the vehicle contains evidence of the offense of arrest. When these justifications are absent, a search of an arrestee's vehicle will be unreasonable unless police obtain a warrant or show that another exception to the warrant requirement applies." (Id. at pp. 1723-1724.) We will refer to this summarily as appellant's "Gant argument."⁵

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