State of Iowa v. Patrick Scullark

Summary

The court held that officers constitutionally searched Scullark’s fanny pack incident to his lawful custodial arrest because the pack was attached to his person when the arrest began. The search was governed by the categorical rule for searches of an arrestee’s person, not the reaching-distance limitation applicable to searches of an area within an arrestee’s immediate control. The court also held that Scullark’s conditional guilty plea satisfied the statutory interest-of-justice requirement, vacated the court of appeals decision, and affirmed the district court’s denial of suppression.