of a house is to be upheld as incident to an arrest, that arrest must take place inside the house.... ” Vale, 399 U.S. at 33-34, 90 S.Ct. 1969. In Vale, officers appeared at Vale’s residence to execute two warrants for his arrest and observed what appeared to be a drug transaction involving Vale outside the home. Before Vale could reenter the home, he was arrested. Officers made a “cursory inspection of the house to ascertain if anyone else was present.” Id. at 33, 90 S.Ct. 1969. The Supreme Court specifically rejected the proposition “that an arrest on the street can provide its own ‘exigent circumstance’ so as to justify a warrantless search of the arrestee’s house.” Id. at 35, 90 S.Ct. 1969. See also Chimel v. California, 395 U.S. 752, 763, 89 S.Ct. 2034, 23 L.Ed.2d 685 (1969) (<HOLDING>); State v. Futch, 715 So.2d 992 (Fla. 2d DCA
holding that the permissible scope of a search incident to arrest includes the contents of a cell phone found on the arrestees person holding that search incident to arrest may encompass arrestees person and area from within which he might gain possession of weapon or destructible evidence but there is no justification for routinely searching any room other than that in which arrest occurs recognizing that a search incident to a lawful arrest permits a law enforcement officer to conduct a warrantless search of a container located in the area of the arrestees immediate control holding warrantless search of motel room after occupant was arrested outside room for drug possession could not be justified as search incident to arrest absent other exigent circumstances holding that search of golf bag was not legal as search incident to arrest because it was not in passenger compartment of vehicle or otherwise within arrestees immediate control