People v. Catanzarite

In People v. Catanzarite, 211 Mich App 573; 536 NW2d 570 (1995), the defendant, who had been stopped for towing a trailer without a license plate, was detained while the police confirmed the existence of a warrant for his arrest. A leather bag was seized from the defendant and placed in the police car during this process. After the police confirmed the warrant, the defendant was arrested and handcuffed. The police then searched the bag and found cocaine. The Court held that the search was reasonable, noting that the defendant was in actual possession of the bag before he was placed under arrest, and that the search occurred within minutes of his arrest. Id. at 582.