What is the current state of the law on warrantless searches in possession of electronic cigarettes?

We have held that "once an item in an individual's possession has been lawfully seized and searched, subsequent searches of that item, so long as it remains in the legitimate uninterrupted possession of the police, may be conducted without a warrant." Burnette, 698 F.2d at 1049. This is so because, following a lawful search incident to arrest, "the individual's expectation of privacy in the property is significantly reduced." United States v. Holzman, 871 F.2d 1496, 1505 (9th Cir.1989).