Gray v. State (1990)
In Gray v. State, 798 P.2d 346 (Alaska App. 1990) the Court applied and further defined the limits of Zehrung v. State.
Gray was arrested on an outstanding misdemeanor warrant for contempt of court. Bail had already been set on the warrant. Correctional officers at the Matanuska Pretrial Correctional Facility discovered cocaine after removing all articles from Gray's pockets.
The Court stated the following:
Whatever right correctional officers might have, under Zehrung, to conduct immediate "patdown" searches for weapons in cases such as Gray's, that right certainly does not extend to the type of search involved here. A "patdown" is just that -- a limited, external probing of clothing or articles for signs of possible weapons. Ordinarily, the permissible scope of a "patdown" is exceeded when the search extends beyond the exterior of a person's clothing or possessions and intrudes into pockets and closed containers.