State v. Gant
In State v. Gant, 216 Ariz. 1, 216 Ariz. 1, 162 P.3d 640 (Ariz. 2007), the Arizona Supreme Court examined the search incident to arrest exception as applied to the Fourth Amendment. 216 Ariz. at 1, P1, 162 P.3d at 641.
That issue prompted a three-two division on the court, but the search incident to arrest exception is not at issue here.
Gant dealt with an arrested person, secured and handcuffed in the back of a patrol car, with a search then being conducted of the vehicle that the arrested person had been previously driving.
The search incident to arrest exception was at issue. Id. at PP3-4.