terms directly applicable to this case: [Warrantless searches of luggage or other property seized at the time of an arrest cannot be justified as incident to that arrest either if the “search is remote in time or place from the arrest,” or no exigency exists. Once law enforcement officers have reduced luggage or other personal property not immediately associated with the person of the arrestee to their exclusive control, and there is no longer any danger that the arrestee might gain access to the property to seize a weapon or destroy evidence, a search of that property is no longer an incident of the arrest. United States v. Chadwick, 433 U. S. 1, 15 (97 SCt 2476, 53 LE2d 538) (1977) (citation and footnote omitted). See also Satterfield v. State, 256 Ga. 593, 597 (351 SE2d 625) (1987) (<HOLDING>). In this case, Appellant had already been
recognizing that the justification for a protective sweep of even a few minutes would be questionable in light of the officers concession that after arresting the defendant in front of his house the officer could have just put the defendant in the car and driven away holding that the seizure of a shotgun that the police found while searching a house a few minutes after the defendant and his girlfriend were removed and put into police cars could not be justified as a search incident to his arrest holding that the protective sweep incident to the defendants arrest in front of his house on suspicion of murder was not justified because the evidence that an accomplice was involved in the murder did not equate to evidence that someone would be hiding out in the defendants house a month after the crime occurred and at the time of the arrest the officers were not chasing the defendant from a crime scene holding that while search incident to arrest could not justify search in that case probable cause plus exigency justified search holding that search conducted between 30 and 45 minutes after defendant was arrested handcuffed and placed in rear of police vehicle lacked contemporaneity requirement of search incident to arrest