his immediate control” — construing that phrase to mean the area from within which he might gain possession of a weapon or destructible evidence. Chimel v. California, 395 U.S. 752, 763, 89 S.Ct. 2034, 2040, 23 L.Ed.2d 685 (1969). We have no difficulty in holding that the district court did not err in ruling an area about 15 feet away from a handcuffed and guarded arrestee is not within the “immediate control” of the arrestee. The state submits no authority holding the Chimel “immediate-control” test is satisfied under similar facts. Instead, the state argues that a “bright-line rule” should apply. There is a “bright-line rule” applicable to the scope of searches of vehicles incident to arrest. See New York v. Belton, 453 U.S. 454, 460, 101 S.Ct. 2860, 2864, 69 L.Ed.2d 768 (1981) (<HOLDING>). There is another “bright-line rule” that
holding that after policeman has made a lawful custodial arrest of the occupant of an automobile he may as a contemporaneous incident of that arrest examine the contents of any containers including glove compartments found within the passenger compartment 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 holding police incident to arrest of occupant of automobile may search entire passenger compartment of vehicle holding that after making an arrest of the driver of a vehicle the police may search the passenger compartment of the vehicle holding when a policeman has made a lawful custodial arrest of the occupant of an automobile he may as a contemporaneous incident of that arrest search the passenger compartment of that automobile