People v. Bullwinkle

In People v. Bullwinkle (1980) 105 Cal.App.3d 82, the court justified the search of the arrestee's purse when the arrestee took it with her to the police station after having been arrested. After arriving at the police department, the officers searched the purse and discovered incriminating evidence. The Bullwinkle court held that a person who is under arrest and subject to being booked into jail must yield to a search of his or her personal effects. The court correctly held that booking searches traditionally extend to a purse. The court noted, "Purses and wallets are entirely different from automobiles. The contents of automobiles 'may be readily and adequately protected by locking the vehicle.' The contents of purses and wallets, on the other hand, are easily susceptible to theft since purses and wallets cannot normally be locked. " ( Id., at p. 89.)