California, United States of America
The following excerpt is from People v. Loudermilk, 195 Cal.App.3d 996, 241 Cal.Rptr. 208 (Cal. App. 1987):
As an alternate independent ground, we conclude that the seizure of the wallet was also justified as being incident to a lawful arrest. (See People v. Superior Court (Kiefer) (1970) 3 Cal.3d 807, 812-813, 91 Cal.Rptr. 729, 478 P.2d 449.)
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