On Point blog, page 2 of 2

Arrest, Search Incident to – Automobile Passenger’s Property Incident to Arrest of Driver

State v. Jordan A. Denk2008 WI 130, on certification
For Denk: Lora B. Cerone, SPD, Madison Appellate

Issue: Whether the police may search, incident to the arrest of the driver, a passenger’s personal belongings (in this instance: an eyeglass case) found outside the vehicle.

Holding:

¶56      The record indicates that Officer Hahn was concerned about the possible threat posed by Denk as well.

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Exigency — Automobile Exception to Warrant Requirement

State v. Robert J. Pallone, 2000 WI 77, 236 Wis. 2d 162, 613 N.W.2d 568, affirming State v. Pallone, 228 Wis. 2d 272, 596 N.W.2d 882
For Pallone: Steven J. Watson

Issue: Whether the search of a vehicle passenger’s duffel bag, following the driver’s arrest for the forfeiture offense of having open intoxicants, was proper.

Holding: The search was justified as both incident to arrest and as based on probable cause.

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Arrest — Search Incident to Arrest — Automobile Passenger’s Property Incident to Arrest of Driver

State v. Robert J. Pallone, 2000 WI 77, 236 Wis. 2d 162, 613 N.W.2d 568, affirming State v. Pallone, 228 Wis. 2d 272, 596 N.W.2d 882
For Pallone: Steven J. Watson

Issue: Whether the search of a vehicle passenger’s duffel bag, following the driver’s arrest for the forfeiture offense of having open intoxicants, was proper.

Holding: The search was justified as both incident to arrest and as based on probable cause.

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