In general, the search of an arrestee's vehicle located a substantial distance from the doorstep of his home where he was arrested could not be justified as a search incident to arrest.

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The Supreme Court in Arizona v. Gant (2009) held that police may search a vehicle incident to a recent occupant’s arrest only if the arrestee is within reaching distance of the passenger compartment at the time of the search or it is reasonable to believe the vehicle contains evidence of the offense of arrest. A vehicle located a substantial distance from the arrestee's location at the time of arrest would not meet these criteria, thus such a search could not be justified as a search incident to arrest.

In General, the Search of an Arrestee's Vehicle Located a Substantial