Sanchez, Reinaldo, 538 S.W.3d 545

Early morning: Officer Martinez found Sanchez asleep in a parked Jeep; dispatch revealed outstanding local traffic warrants and she placed him under arrest for those warrants.
During a search of Sanchez’s person incident to that arrest, the officer found a cigarette box containing two small baggies that appeared to be cocaine.
After discovering the drugs on Sanchez’s person, the officer searched the Jeep and found a pouch with a baggie of a substance that field-tested positive for cocaine.
Trial court suppressed the evidence found in the Jeep (concluding the vehicle search was not justified as a search incident to the traffic-warrant arrest) but denied suppression of the drugs found on Sanchez’s person.
The court of appeals affirmed, holding the vehicle search could not be justified by the later-discovered drug offense because the “offense of arrest” for search-incident-to-arrest purposes was the traffic offenses that gave rise to the arrest.
The Court of Criminal Appeals granted review and considered whether discovery of a new offense on the arrestee’s person, after an initial arrest for a different offense but before searching the vehicle, can justify a vehicle search incident to arrest.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Sanchez)	Held
Whether a vehicle search incident to arrest can be justified by an offense discovered on the arrestee’s person after an initial arrest for a different offense	The discovery of cocaine on Sanchez’s person gave officers probable cause to arrest for a drug offense, so it was reasonable to believe evidence of that drug offense might be in the vehicle, justifying the vehicle search under Gant	The only relevant "offense of arrest" was the traffic warrants; a later-discovered offense cannot retroactively change the basis for the vehicle search	Yes. The Court held that discovery of drugs on the person after an arrest for other offenses can supply a new basis for arrest; if probable cause for the newly discovered offense exists and the search is close in time to arrest, a vehicle search incident to arrest is justified.

New York v. Belton, 453 U.S. 454 (permitting warrantless search of passenger compartment incident to lawful vehicle occupant arrest)
Arizona v. Gant, 556 U.S. 332 (limiting Belton: vehicle search incident to arrest only if arrestee unsecured/within reaching distance or evidence of the offense of arrest might be found in the vehicle)
Thornton v. United States, 541 U.S. 615 (Scalia concurrence endorsed rule that evidence of the crime of arrest might reasonably be found in the vehicle)
Devenpeck v. Alford, 543 U.S. 146 (probable cause judged by facts known to officer at time of arrest)
Rawlings v. Kentucky, 448 U.S. 98 (timing/formalities of arrest do not necessarily defeat a valid search incident to arrest)
United States v. Ross, 456 U.S. 798 (discussed but not relied on here; referenced auto-search doctrine)
Owens v. Commonwealth, 291 S.W.3d 704 (Ky. 2009) (similar holding that discovery of drugs on person can justify vehicle search incident to arrest)
United States v. Randolph, 628 F.3d 1022 (8th Cir. 2011) (reached similar conclusion applying Gant)