Does Gant's exception to the Fourth Amendment's warrant requirement permit searches on probable-cause, reasonable-suspicion or a categorical-approach based on the crime-of-arrest?

QUESTION PRESENTED Arizona v. Gant, 556 U.S. 332, 351 (2009), authorizes the search of a vehicle incident to an arrest when “it is reasonable to believe the vehicle contains evidence of the offense of arrest.” Courts around the country have come to different conclusions about what is required under this standard. Some hold Gant requires something like probable cause, others that reasonable suspicion is sufficient. Still other courts reject any approach and hold that the lawfulness of a Gant search is categorically determined by the offense of the arrest. The question presented is: Does Gant’s exception to the Fourth Amendment’s warrant requirement permit searches on probable cause, reasonable suspicion or a categorical approach based on the crime of arrest? ii