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Fourth Circuit Extends Gant’s Automobile Search-Incident-to-Arrest Framework to Searches of Non-Vehicular Containers

The U.S. Court of Appeals for the Fourth Circuit extended the holding in Arizona v. Gant, 556 U.S. 332 (2009) (vehicle may be searched incident to arrest without a warrant if police reasonably believe that the arrestee “could have accessed his car at the time of ...

 

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