and searched; there must be probable cause or reasonable suspicion of criminal activity. Items in plain view may be seized; areas that could potentially hide weapons may also be searched. With probable cause to believe evidence is present, police officers may search any area in the vehicle. However, they may not extend the search to the vehicle's passengers without probable cause to search those passengers or consent from the passengers. In Collins v. Virginia (2018), the Court ruled that the motor vehicle exception did not apply to searches of vehicles parked within a residence's curtilage. In Arizona v. Gant (2009), the Court ruled that a law enforcement officer needs a warrant before searching a motor vehicle after an arrest of an occupant of that vehicle, unless 1) at the time of the search the person being arrested is unsecured and within reaching distance of the passenger compartment of the vehicle or 2) police officers have reason to believe evidence for the crime for which the person is being arrested will be found in the vehicle. Searches incident to a lawful arrest A common law rule from Great Britain permits searches incident to an arrest without a warrant. This rule has been applied in American law, and has a lengthy common law history. The justification for such a search is to prevent the arrested individual 1.) from destroying evidence or 2.) using a weapon against the arresting officer by disarming the suspect. The U.S. Supreme Court ruled that "both justifications for the search-incident-to-arrest exception are absent and the rule does not apply" when "there is no possibility" the suspect could gain access to a weapon or destroy evidence. In Trupiano v. United States (1948), the Supreme Court held that "a search or seizure without a warrant as an incident to a lawful arrest has always been considered to be a strictly limited right. It grows out of the inherent necessities of the situation at the time of the arrest. But there must be something more in the way of necessity than merely a lawful arrest." In United States v. Rabinowitz (1950), the Court reversed Trupiano, holding instead that the officers' opportunity to obtain a warrant was not germane to the reasonableness of a search incident to an arrest. Rabinowitz suggested that any area within the "immediate control" of the arrestee could be searched, but it did not define the term. In