The case of United States v. Rabinowitz was the first to set limits on the scope of a search incident to arrest.

Name: The case of United States v. Rabinowitz was the first to set limits on the scope of a search incident to arrest.
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The case of United States v. Rabinowitz was the first to set limits on the scope of a search incident to arrest, holding that the search must be limited to the area within the arrestee's immediate control.

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