In State v. Pierce, 136 N.J. 184, 642 A.2d 947 (1994), the New Jersey Supreme Court held that vehicular searches were not automatically authorized following arrests for motor vehicle offenses, thereby rejecting the bright-line rule of New York v. Belton, 453 U.S. 454, 101 S. Ct. 2860, 69 L. Ed. 2d 768 (1981). In reaching its conclusion, the Court took note of cases, standards and commentators that had questioned the propriety of detention or arrest "in respect of offenses that pose little threat to police safety." Pierce, supra, 136 N.J. at 193, 642 A.2d 947. The Court, Id. at 194, 642 A.2d 947, quoted Professor LaFave's hope that the United States Supreme Court would one day conclude, that there are some constitutional limits upon the use of 'custodial arrests' as the means for invoking the criminal process when relatively minor offenses are involved. Such a holding would be most desirable, as it would address specifically a current problem of considerable seriousness: the arbitrariness and inequality which attends unprincipled utilization of the 'custodial arrest' and citation alternatives. Moreover, it would substantially diminish the opportunities for pretext arrests . . .2 Wayne R. La Fave, Search and Seizure, 5.2(g), at 465 (2d ed.1987)