In Rawlings v. Kentucky, 448 U.S. 98 (1980), during a warrant-authorized search of a house, one of the occupants was ordered to empty her purse. 448 U.S. at 101. When she did, it was observed to contain controlled substances. Id. The occupant then turned to Rawlings, who was standing nearby, and told him "to take what was his." Id. Rawlings "immediately claimed ownership" of the drugs. Id. The police arrested Rawlings but not before searching him and finding $ 4,500 and a knife. Id. The pre-arrest search of Rawlings' person was subsequently upheld as a valid search incident to an arrest, regardless of the fact that it had preceded his arrest, a distinction which the Court, as previously noted, did not feel was "particularly important. " See id. at 111. The Supreme Court to declared that, "where the formal arrest followed quickly on the heels of the challenged search of petitioner's person, we do not believe it particularly important that the search preceded the arrest rather than vice versa."