What is the test to preserve the issue of search incident to arrest?

In our view, merely typing out the words "search incident to arrest" at the district court level was insufficient to preserve the issue for appeal. The government was required to offer some argument or development of its theory. It failed to do so, and has therefore waived the issue. Cf. United States v. Braunig, 553 F.2d 777, 780 (2d Cir.), cert. denied, 431 U.S. 959, 97 S.Ct. 2686, 53 L.Ed.2d 277 (1977) ("[W]here a party has shifted his position on appeal and advances arguments available but not pressed below ... and where that party has had ample opportunity to make the point in the trial court in a timely manner ... waiver will bar raising the issue on appeal.").

(2) Inventory incident to detainer