S.Ct. at 2040 (1969) (emphasis added); see also Young v. United States, 670 A.2d 903, 909 (D.C.1996) (upholding search where “search was limited ... to the two places where the officers had concrete reason to believe weapons might be” and “there was no general rummaging through drawers or closets”). “No consideration relevant to the Fourth Amendment suggests any point of rational limitation, once the search is allowed to go beyond the area from which the person arrested might obtain weapons or evidentiary items.” Chimel, 395 U.S. at 766, 89 S.Ct. at 2041. Against this legal background, we conclude that the record in this case does not contain sufficient factual information to conclude that the search of the tin was reasonable as a search incident to arrest. See Wells, 928 P.2d at 389 (<HOLDING>); Harrison, 805 P.2d at 784 n. 26 (noting “our
holding a person may consent to warrantless searches as a condition of a suspended sentence holding that warrantless searches of cell phones incident to arrest should not be allowed because such searches cannot be justified by officer safety or the preservation of evidence given the privacy implications inherent in cell phone data searches holding state has burden of showing exception to prohibition against warrantless searches applies holding that community caretaking exception applies only to automobile searches holding that the debtor has the burden of showing that collateral estoppel applies