In Arizona v. Grant, the Court revisited the bright line rule established in Benton and:

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In Arizona v. Gant, the Supreme Court significantly limited the scope of the search incident to arrest exception established in New York v. Belton, ruling that police may only search a vehicle incident to a recent occupant's arrest if the arrestee is within reaching distance of the passenger compartment at the time of the search or if it is reasonable to believe the vehicle contains evidence of the offense of arrest.

In Arizona V