In a recent case, State v. Michaels, the Washington Supreme Court announced a new rule for search and seizure incident to an arrest: the purpose of the arrest circumscribes the area and nature of the search.
Washington Case Law,
Criminal Law—Search Incident to an Arrest,
Wash. L. & Rev.
Available at: https://digitalcommons.law.uw.edu/wlr/vol38/iss2/10