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From Lorman Education Services
Motor Vehicle Searches: Impact of the Arizona v. Gant Decision
.... After years of a broad interpretation of Belton by both Circuit Courts of Appeals and the Supreme Court itself in Thorton v. United States, 541 U.S. 615 (2004), that allowed police to conduct a search even after a suspect is in custody and no longer a threat to officer safety, the Supreme Court has significantly limited police authority to conduct searches incident to an arrest in Gant.
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Motor Vehicle Searches: Impact of the Arizona v. Gant Decision
