In United States v Robinson, 414 U.S. 218 (1973), the Supreme Court recognized that "the danger to the police officer flows from the fact of the arrest, and its attendant proximity, stress, and uncertainty, and not from the grounds for arrest." Robinson, 414 U.S. at 234, n 5. The Robinson Court relied on the differences between searches incident to lawful custodial arrests and Terry "stop-and-frisk" searches to reject an argument that the limitations established in Terry should be applied to a search incident to arrest. Robinson, 414 U.S. at 228. There are two historical rationales for the "search incident to arrest" exception to the warrant requirement of the Fourth Amendment: (1) the need to disarm the suspect in order to take him into custody; (2) the need to preserve evidence for later use at trial. A custodial arrest involves "danger to an officer" because of "the extended exposure which follows the taking of a suspect into custody and transporting him to the police station." Robinson, 414 U.S. at 234-235.