In People v. Marsh, 20 NY2d 98, 228 N.E.2d 783, 281 N.Y.S.2d 789 (1967), the defendant was arrested pursuant to an arrest warrant issued in 1965 for a 1963 traffic violation (speeding). Upon making the arrest, the police searched the defendant and found a sheet of paper which implicated him in illegal gambling. Finding that the arrest pursuant to a warranted was governed by the same rules which would apply if the defendant had been arrested immediately following the traffic infraction, the Court of Appeals carved out a rule that traffic arrests do not warrant a generalized search incident to such arrests. The Court of Appeals in Marsh stated at 101: "we can only conclude that even though the rules of criminal law are generally applicable to traffic violations (People v. Byron, 17 NY2d 64, 66, 215 N.E.2d 345, 268 N.Y.S.2d 24), the legislature never intended to authorize a search of a traffic offender unless, when the vehicle is stopped, there are reasonable grounds for suspecting that the officer is in danger or there is probable cause for believing that the offender is guilty of a crime rather than merely a simple traffic infraction." Subsequently, in People v. Adams, 32 NY2d 451, 299 N.E.2d 653, 346 N.Y.S.2d 229 (1973), the rule enunciated in Marsh was extended to arrests for traffic misdemeanors. The Court held that the police are not authorized to conduct a search incident to an arrest for a traffic infraction unless the officer has reason to fear an assault or has probable cause for believing that the driver committed a crime. In the Court's view, the Legislature did not intend traffic offenders to be regarded as and treated like criminals.