The U.S.Supreme Court limited the scope of search incidental to arrest to the area within the suspect's "immediate control" in

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The U.S. Supreme Court limited the scope of search incidental to arrest to the area within the suspect's "immediate control" in Chimel v. California (1969). This means that a warrantless search of the area within the suspect's immediate control can be carried out without violating the Fourth Amendment's prohibition against unreasonable searches and seizures. However, the search must be limited to the area that the suspect could reach or where evidence could be destroyed.

The USSupreme Court Limited the Scope of Search Incidental to Arrest