the Court authorized a narrow search of the arrestee’s “person and the area from within which he might have obtained either a weapon or something that could have been used as evidence against him.” 395 U.S. at 768, 89 S.Ct. 2034. Such a search, justified by the State’s interests in the safety of the arresting officer and in preserving evidence, is strictly limited to the area “within [the arrestee’s] immediate control” — “the area into which an arrestee might reach in order to grab a weapon or evidentiary items.” Id. at 763, 89 S.Ct. 2034. See also Michigan v. Long, 463 U.S. 1032, 1049-50, 103 S.Ct. 3469, 77 L.Ed.2d 1201 (1983); Terry v. Ohio, 392 U.S. 1, 27-28, 88 S.Ct. 1868, 20 L.Ed.2d 889 (1968). Later, in Buie, the Court refined its analysis in Chimel. It noted the “int d Cir.1995) (<HOLDING>). Lemus’s living room not only immediately
holding that defendant had reasonable expectation of privacy in a hotel room rented by relatives when he had a key to the room and permission to use the room at will holding on to objects in the room holding that buie permitted a search of an open storage unit when the suspect was arrested immediately outside holding that under buie the second room in a tworoom apartment immediately adjoined the first room in which the suspect was arrested holding that buie permitted the search of a bedroom fifteen feet down a hallway in which the suspect was arrested