Whether the Fourth Amendment permits a warrantless search incident to arrest when the arrestee is secured and not within reaching distance of a closed container

QUESTION PRESENTED Whether this Court’s opinion in Arizona v. Gant, 556 U.S. 332 (2009) created a two-part test that requires an arrestee to be unsecured and within reaching distance of a closed container for law enforcement officials to conduct a warrantless search incident to arrest.