In what circumstances will a police officer be able to search a person's lunchbox without a warrant?

The Attorney General in Pace argued that Pace could have no justifiable greater expectation of privacy in his lunchbox, a thing that he was carrying, than he would have in things carried on his person when searched incident to a lawful arrest. The Attorney General urges likewise in the instant case. But we rejected mass and locks as having any relevancy to a person's legitimate expectations of privacy where the authorities are concerned. (Id., 92 Cal.App.3d at pp. 205-206, fn. 5, 154 Cal.Rptr. 811.) We pointed out that "The search of a person incident to arrest, however, is not permitted because of the absence of a legitimate expectation of privacy.... A warrantless search of the person is permitted because of the need to protect the arresting officers as well as others and as a precaution against the destruction of evidence." (Id., at p. 206, 154 Cal.Rptr. 811.) Further, in Pace, supra, at page 204, 154 Cal.Rptr. 811, this division opined that in California "(t)he warrant requirement must be satisfied in every case where exigent circumstances do not justify ignoring it." We further noted that necessarily this is the case because California constitutional principle placed the burden on the People to justify a warrantless search, citing People v. Norman (1975) 14 Cal.3d 929, 933, 123 Cal.Rptr. 109, 538 P.2d 237. In Norman, a warrantless search of a soft tobacco pouch, dropped by the defendant incident to his custodial arrest for traffic offenses which revealed contraband narcotics, was held to be illegally seized in violation of article I, section 13 of the California Constitution. (Id., at p. 938, 123 Cal.Rptr. 109, 538 P.2d 237.) The Norman court, at page 936, 123 Cal.Rptr. 109, 538 P.2d 237, analyzed the dropped (under the defendant's van) tobacco pouch as an object that was within the arrestee's immediate control or possession, but concluded that the evidence was insufficient to establish probable cause for a warrantless protective search for weapons or for any other justifiable reason, i.e., instrumentalities or fruits of crime or contraband.