Can police search the trunk of a car incident to a lawful arrest of the driver?

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The essential idea is that a search incident to arrest is limited to the arrestee and the area within the arrestee’s immediate control, mainly to protect officer safety and prevent the destruction of evidence. The trunk of a car is not part of that immediate control, and once the driver is arrested, police can’t automatically search the trunk just because of the arrest.

To search the trunk, the police would need something more: probable cause to believe the trunk contains evidence, and either a warrant or a warrantless justification such as consent or a different exception (for example, the automobile exception if there’s probable cause to search the vehicle as a whole). There are separate rules about when a vehicle’s passenger compartment may be searched after an arrest (as clarified in Chimel and later cases like Arizona v. Gant), but those rules do not extend to the trunk without additional justification.

So, without probable cause or consent (or a warrant or another applicable exception), the trunk cannot be searched incident to the lawful arrest of the driver.