What is the test for a search warrant under California Vehicle Code section 22651?

In Virgil v. Superior Court, Supra, 268 Cal.App.2d 127, 73 Cal.Rptr. 793, the driver of the vehicle was arrested for reckless driving (Veh.Code, 23103). After the driver and two passengers were removed from the vehicle, the arresting officer commenced an examination of the inside of the vehicle for the purpose of 'inventorying the contents' incident to its removal from the highway pursuant to Vehicle Code section 22651. He found marijuana which petitioners contended was illegally seized. The court stated (pp. 132--133, 73 Cal.Rptr. p. 796): '* * * We hold that the Constitution does not permit an otherwise unreasonable search of a car simply because the police have statutory authority

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