The Supreme Court affirmed that police have the power to conduct searches and seize evidence, even when done during an arrest that turns out to have violated state law.  Defendant was convicted for possessing cocaine with the intent to distribute, but his conviction was reversed by the Virginia Supreme Court. The court reasoned that since arresting officers should have issued defendant a citation for driving with a suspended license under state law rather than arresting him and the Fourth Amendment did not permit search incident to citation, an arrest search violated the Fourth Amendment.
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