California, United States of America
The following excerpt is from People v. Flores, G048569 (Cal. App. 2014):
An officer may thoroughly search an individual incident to a lawful arrest. (See Rawlings v. Kentucky (1980) 448 U.S. 98, 110-111.) Importantly, it does not matter that the search preceded the arrest rather than vice versa, so long as the "formal arrest follow[s] quickly on the heels of the challenged search." (Ibid.) That is what happened here.
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