?Based on Chimel v.California,the key question in deciding whether or not a warrant is required to open a container seized incident to arrest of a person is:

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According to the Supreme Court decision in Chimel v. California, a warrantless search of a container seized incident to an arrest is permissible only if the container is both "closely associated with the person of the arrestee" and still within the "immediate control" of the arrestee at the time of the search. Thus, option D is the best choice because it includes both of these important criteria. A and B are similar, but do not capture both elements together, while C is not a relevant consideration in this context.

?Based on Chimel V