For an item to be validly seized during a search incident to arrest, the police must have probable cause to seize the item, but they do not need to immediately recognize the item's evidentiary value.

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For an item to be validly seized during a search incident to arrest, the police must have probable cause to believe the item is evidence of a crime, contraband, or otherwise subject to seizure. They must recognize its evidentiary value at the time of the search.

For an Item to Be Validly Seized During a Search