United States v. Robinson

Robinson (defendant) was arrested for driving with an expired license; during a pat-down, the arresting officer felt an object in his breast pocket, removed it, discovered it was a cigarette packet, and opened it to find heroin capsules. The court of appeals held the search invalid, reasoning a search incident to arrest is permissible only to look for evidence of the specific crime or to check for weapons, and since no license-related evidence could be on Robinson's person and the officer knew the object wasn't a weapon, only a limited weapons search was justified.