In People v. Adams (32 N.Y.2d 451 [1973]), the rule enunciated in Marsh was extended to arrests for traffic misdemeanors. The defendant in that case was stopped by a policeman for driving his car with high beam headlights, following which the officer discovered that the vehicle identification number appeared to be altered. The officer arrested the defendant on a misdemeanor charge of possession of a motor vehicle on which the identification number has been altered in violation of Section 422 of the Vehicle and Traffic Law. A search was immediately conducted of the defendant's person, during which marijuana and drug paraphernalia was discovered. In concluding that a search incident to arrest was not warranted, the Court reasoned: "Having produced his license and registration and in the absence of any showing that the defendant was unable to explain satisfactorily or answer any questions concerning the identification number, it is unlikely and certainly unreasonable to assume that, in the circumstances of this case, a search of the defendant's person was properly an incident to the arrest. Lacking is any foundation for a justifiable belief that a search would satisfy the constitutionally protected requirements therefor. We hold in this case that a violation of section 422 of the Vehicle and Traffic Law, without more, will not sustain this search. In reaching this conclusion we have carefully weighed the need to search along with the governmental interest to justify the search, against the intrusion upon the constitutionally protected interests of private citizens."