Opinion of the Court
was reasonable even though there was no concern about the loss of evidence, and the arresting officer had no specific concern that Robinson might be armed. Id., at 236. In doing so, the Court did not draw a line between a search of Robinson's person and a further examination of the cigarette pack found during that search. It merely noted that, "[hjaving in the course of a lawful search come upon the crumpled package of cigarettes, [the officer] was entitled to inspect it." Ibid. A few years later, the Court clarified that this exception was limited to "personal property . . . immediately associated with the person of the arrestee." United States v. Chadwick, 433 U. S. 1, 15 (1977) (200-pound, locked footlocker could not be searched incident to arrest), abrogated on other grounds by California v. Acevedo, 500 U. S. 565 (1991).
The search incident to arrest trilogy concludes with Gant, which analyzed searches of an arrestee's vehicle. Gant, like Robinson, recognized that the Chimel concerns for officer safety and evidence preservation underlie the search incident to arrest exception. See 556 U. S., at 338. As a result, the Court concluded that Chimel could authorize police to search a vehicle "only when the arrestee is unsecured and within reaching distance of the passenger compartment at the time of the search." 556 U. S., at 343. Gant added, however, an independent exception for a warrantless search of a vehicle's passenger compartment "when it is 'reasonable to believe evidence relevant to the crime of arrest might be found in the vehicle.'" Ibid. (quoting Thornton v. United States, 541 U. S. 615, 632 (2004) (SCALIA, J., concurring in judgment)). That exception stems not from Chimel, the Court explained, but from "circumstances unique to the vehicle context." 556 U. S., at 343.
Ill
These cases require us to decide how the search incident
