State v. Snapp, 174 Wash. 2d 177

Two consolidated Washington cases address warrantless vehicle searches incident to arrest under article I, section 7.
Snapp was stopped for suspected traffic-related issues; police later searched the Escort trunk, leading to identity-theft charges and suppression disputes.
Wright was stopped for a headlight infraction; after interrogation, a canine search revealed drugs and led to drug offenses.
The Court of Appeals upheld a Thornton-based vehicle-search incident to arrest; this Court granted discretionary review.
The Court holds that the Thornton form of the search incident to arrest does not apply under article I, section 7 and reverses the Court of Appeals in both Snapp and Wright.
Wright’s stop is also analyzed for reasonableness and pretext; the stop is upheld as not pretextual.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Thornton exception applies under article I, section 7	Snapp/Wright contend Thornton should be recognized.	State contends Thornton aligns with Fourth Amendment but not article I,7.	Thornton exception not valid under article I,7.
Whether a modified probable-cause vehicle search is permissible under article I,7	Ringer/Buelna Valdez support vehicle search with evidence-of-arrest focus.	State argues the vehicle search is justified by probable cause to find evidence of arrest.	No valid form of the Thornton-like or probable-cause-to-find-evidence search under article I,7.
Whether the Wright traffic stop was justified and non-pretextual	Wright argues stop was pretextual for an unlawful search.	State asserts stop based on reasonable suspicion of a traffic infraction and area context.	Stop not pretextual; stop justified.

Arizona v. Gant, 556 U.S. 332 (2009) (vehicle search incident to arrest limited to arrestee within reach or probable evidence in vehicle (Fourth Amendment))
State v. Patton, 167 Wash.2d 379 (2009) (art. I, str. 7 vehicle search-incident-to-arrest guidance; after arrestee secured, no automatic search)
State v. Buelna Valdez, 167 Wash.2d 761 (2009) (limits on vehicle search incident to arrest; overruled Stroud's broader scope)
State v. Ringer, 100 Wash.2d 686 (1983) (origins of vehicle search incident to arrest: weapons and evidence preservation)
State v. Stroud, 106 Wash.2d 144 (1986) (expanded vehicle search scope post-arrest (overruled by Buelna Valdez))
State v. Garcia-Salgado, 170 Wash.2d 176 (2010) (distinct state constitutional rights; no automatic application of federal rules)
State v. Tibbles, 169 Wash.2d 364 (2010) (limits on probable-cause-based vehicle searches under article I,7)
State v. Afana, 169 Wash.2d 169 (2010) (recognition of privacy interests under article I,7 in vehicle contexts)
Grande v. Wash., 164 Wash.2d 135 (2008) (probable cause to search vehicle for drug-related evidence; not controlling here)