In New York v. Belton, 453 U.S. 454 (1981), the officer stopped a vehicle for excessive speeding; Belton was one of four occupants in the vehicle. None of the occupants owned the vehicle. Because the officer smelled burnt marijuana and saw an envelope on the floor of the car marked "'Supergold,'" which the officer associated with marijuana, all occupants were arrested for possession of marijuana and ordered out of the car. The officer picked up the envelope, found it contained marijuana, and searched the passenger compartment of the car. The officer found Belton's jacket in the back seat, unzipped a pocket, and discovered cocaine. Belton was indicted for possession of cocaine. Because articles inside the vehicle's passenger compartment are generally within the areas where an arrestee might reach to retrieve a weapon or evidence, the Belton Court held that an officer who has lawfully arrested an occupant of a vehicle may, as a contemporaneous incident of that arrest, search the passenger compartment of that vehicle and examine the contents of any open or closed containers found within the passenger compartment. 453 U.S. at 460-61. A "'container'" was defined to include closed or open glove compartments and consoles but not trunks. 453 U.S. at 460, n. 4. The justification for searching containers was "not that the arrestee has no privacy interest in the container, but that the lawful custodial arrest justified the infringement of any privacy interest the arrestee may have." 453 U.S. at 461. The Belton Court held that the search of Belton's jacket was an area within his immediate control and within the meaning of the Chimel v. California decision; thus, the search was constitutional. 453 U.S. at 462. The defendant challenged the scope of an otherwise valid search of his car, contending the officers had searched parts of the passenger compartment he could not have possibly reached had he desired to destroy evidence or seize a weapon. 453 U.S. at 455-56, 101 S. Ct. at 2861-62. Rejecting his claim, the Court found that "articles inside the . . . passenger compartment of an automobile are . . . generally . . . within 'the area . . . an arrestee might reach in order to grab a weapon or evidentiary item'" and, therefore, "as a contemporaneous incident" to the lawful arrest, officers were entitled to search the entire passenger compartment of a vehicle. Id. at 460, 101 S. Ct. at 2864. In so holding, the Court emphasized that "'a single, familiar standard is essential to guide police officers'" and implied that it had erected a bright-line rule to relieve officers in the field from having to make hairline distinctions based on subtle nuances. Id. at 458, 101 S. Ct. at 2863. The Court rejected a claim that because the police had control over a jacket taken from a car, the Chimel exception did not justify searching it after its owner had been removed and arrested and could no longer possibly get anything from it. (Id. at p. 462, fn. 5.) The court reasoned that "under this fallacious theory no search or seizure incident to a lawful custodial arrest would ever be valid; by seizing an article even on the arrestee's person, an officer may be said to have reduced that article to his 'exclusive control.'" (Ibid.) In Belton, the court dealt with the scope of a warrantless search of a vehicle incident to the arrest of its occupants, and the court's comments must be understood in that context. The court held that "when a policeman has made a lawful custodial arrest of the occupant of an automobile, he may, as a contemporaneous incident of that arrest, search the passenger compartment of that automobile." (Belton, supra, 453 U.S. at p. 460, ) The United States Supreme Court held that "when a policeman has made a lawful custodial arrest of the occupant of an automobile, he may, as a contemporaneous incident of that arrest, search the passenger compartment of that automobile." Id. at 460. The Court also extended the right to search incident to arrest to any containers found within the passenger compartment of the vehicle if the passenger compartment is within the reach of the arrestee. Id. New York v. Belton created a bright-line rule regarding automobile searches incident to an arrest. A principle underlying Belton is that a search incident to an arrest can encompass an area where the arrestee was not located at the time of the formal arrest, and this is not unreasonable. In Belton cases, the defendant will be arrested outside the vehicle, but a search of the vehicle's interior is still reasonable. The United States Supreme Court has held that this is not an unreasonable intrusion under the Fourth Amendment. This principle is persuasive. A search incident to arrest is not tied to the formalities of the arrest. Idaho courts have recognized this principle in many ways: (1) by applying the Belton rule regarding automobile searches incident to an arrest; (2) by approving searches after the passage of time following the arrest; (3) by approving searches of items not in the possession of the arrestee at the time of the arrest; (4) by approving searches which occur before the formal arrest, where probable cause existed at the time of the search; (5) by validating searches incident to an unlawful arrest through a finding of probable cause to arrest for another crime arising from the same set of operative facts; (6) by approving searches of the interior of a vehicle pursuant to the arrest of the driver, where probable cause to arrest did not arise until the driver was outside of and far away from the vehicle. These cases illustrate that the formalities of an arrest do not necessarily determine the search which may be reasonably performed incident to that arrest. The United States Supreme Court reversed the New York Court of Appeal which had ordered suppression of the evidence on the theory that a "'warrantless search of the zippered pockets of an unaccessible jacket may not be upheld as a search incident to a lawful arrest where there is no longer any danger that the arrestee or a confederate might gain access to the article.'" ( Id., 453 U.S. at p. 456.)