In 2009, what case qualified the earlier New York v. Belton Court decision on conducting searches in passenger compartments of cars only when it is reasonable to believe the arrestee could still have access to the vehicle at the time of the search?

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Arizona v. Gant qualified the New York v. Belton decision by stating that police may search the passenger compartment of a vehicle incident to a recent occupant's arrest only if it is reasonable to believe that the arrestee could access the vehicle at the time of the search or if the police have reason to believe that evidence of the offense for which the person was arrested might be found in the vehicle.

In 2009, What Case Qualified the Earlier New York V