Court of Utah, in applying the good-faith exception to a Belton search, recently cautioned: "If the case law had been ambiguous prior to the time the officers conducted a search later definitively declared unconstitutional, the good-faith exception would not apply and the evidence would be excluded.” Utah v. Baker, 229 P.3d 650, 664 (Utah 2010). 80 . See Belton, supra note 1, 453 U.S. at 460, 101 S.Ct. 2860. 81 . Compare Thornton, supra note 59, 541 U.S. at 622, 124 S.Ct. 2127 (declining to address argument that Belton rule applies only to “recent occupants” of vehicle, while noting that petitioner had conceded "he was in ‘close proximity, both temporally and spatially,’ to his vehicle” when approached by police officer) with Lewis v. United States, 632 A.2d 383, 388-89 (D.C.1993) (<HOLDING>). 82 . See Gant, supra note 2, 129 S.Ct. at
holding that an officer may search a suspects vehicle incident to a lawful arrest holding warrantless search of vehicle was improper where car was not stopped on a highway but was parked at a residence with no occupants inside or near the vehicle and capable of being driven away by the turn of an ignition key holding police incident to arrest of occupant of automobile may search entire passenger compartment of vehicle holding belton did not extend to search of vehicle incident to arrest of individual who has parked locked and walked fifteen to twenty feet away from an automobile before being stopped and arrested holding that belton permits the search of the passenger compartment of an automobile even when the defendant is arrested outside as long as the officer made initial contact while the defendant was inside the automobile