The issuance of a traffic citation alone is not a lawful custodial arrest sufficient to justify a search incident to arrest.

Name: The issuance of a traffic citation alone is not a lawful custodial arrest sufficient to justify a search incident to arrest.
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A traffic citation does not constitute a custodial arrest, which is necessary to justify a search incident to arrest. Therefore, a search incident to arrest cannot be conducted solely based on a traffic citation.

The Issuance of a Traffic Citation Alone Is Not a Lawful