In People v. Troiano (35 NY2d 476, 478, 323 N.E.2d 183, 363 N.Y.S.2d 943 [1974]), the police placed the defendant under arrest pursuant to a warrant issued six days earlier on a misdemeanor charge of driving with a suspended license. The Court upheld a frisk following the arrest, noting that "So long as an arrest is lawful, the consequent exposure to search is inevitable" (Troiano at 478). The Court again acknowledged, however, that there might be an area of traffic violation "arrest" where a full-blown search would not be justified because the alternative of issuing a summons was available or because the arrest was a suspect pretext (id.).