The U.S.Supreme Court has held that only weapons, narcotics, and other items that have an "immediately apparent" connection to a crime can be seized as a result of a search incident to arrest.

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The U.S. Supreme Court has not limited the seizure of items during a search incident to arrest only to those with an "immediately apparent" connection to a crime. The standard for seizing items during such a search is broader, allowing for the seizure of evidence relevant to the crime of arrest or other criminal activity.

The USSupreme Court Has Held That Only Weapons, Narcotics, and Other