Whether police may search a vehicle incident to arrest when the officers have arrested a recent occupant for providing false identification, secured the arrestee in a police car, and established the arrestee's identity

QUESTION PRESENTED In Arizona v. Gant, this Court held, “Police may search a vehicle incident to a recent occupant’s arrest only if the arrestee is within reaching distance of the passenger compartment at the time of the search or it is reasonable to believe the vehicle contains evidence of the offense of arrest.” 556 U.S. 332, 351 (2009). In Davis v. United States, 564 U.S. 229, 236 (2011), this Court affirmed the Eleventh Circuit’s conclusion that this rule does not permit a vehicle search incident to arrest when police officers have arrested a recent occupant for providing false identification, secured the arrestee in a police car, and established the arrestee’s identity. Here, Petitioners were in a parked car, when a police officer approached and asked the two for identification. Petitioners both gave false names. After learning Petitioners’ true identities, the police arrested them for giving false identification and secured them in the back of police cars. The police then searched the vehicle and discovered methamphetamine. The question presented is: Whether police may search a vehicle incident to arrest when the officers have arrested a recent occupant for providing false identification, secured the arrestee in a police car, and established the arrestee’s identity.