justifies a warrantless search of a defendant’s purse, not vice versa. And, as Gant demonstrates, a warrantless search of a purse incident to arrest is itself not appropriate when the purse is secured and “presents no reasonable risk to officer safety or the preservation of evidence.” 216 Ariz. at 7, ¶ 23, 162 P.3d at 646. Obviously, that a person is not in custody is not in itself sufficient justification for a search absent other circumstances. To justify the search of Appellant’s purse, Officer Stewart had to be able to point to particular facts from which he reasonably inferred that Appellant might make use of something dangerous that might be in her purse even once the purse had been taken from her. Sibron v. New York, 392 U.S. 40, 64, 88 S.Ct. 1889, 20 L.Ed.2d 917 (1968) (<HOLDING>) (emphasis added). A general observation that
holding that a police officer may order an individual out of his car and frisk him for weapons if there is a reasonable belief that the individual is armed and dangerous holding intent may be inferred from all facts and circumstances holding that parties may stipulate to facts from which jurisdiction may be inferred holding that to justify detention of a criminal suspect the police officer must be able to point to specific and articulable facts which taken together with rational inferences from those facts reasonably warrant that intrusion holding that an officer must be able to point to particular facts from which he reasonably inferred that the individual was armed and dangerous