What is the test for a search incident to arrest?

Flores's search incident to arrest argument deserves short shrift. As the United States Supreme Court recognized in Arizona v. Gant (2009) 556 U.S. 332 (Gant), the search incident exception to the warrant requirement has a unique application in the context of a vehicle search. "[C]ircumstances unique to the vehicle context justify a search incident to a lawful arrest when it is 'reasonable to believe evidence relevant to the crime of arrest might be found in the vehicle.' [Citation.] In many cases, as when a recent occupant is arrested for a traffic violation, there will be no reasonable basis to believe the vehicle contains relevant evidence. [Citations.] But in others . . . the offense of arrest will supply a basis for searching the passenger compartment of an arrestee's vehicle and any containers therein." (Id., at pp. 343-344.)