When Patrick Scullark was arrested, he was not wearing his fanny pack. He had taken it off and handed it to a friend before being handcuffed and placed in the back of a patrol car. But police nevertheless conducted a thorough search of the bag without a warrant. Scullark argued that the warrantless search violated his Fourth Amendment rights, but on appeal, the Iowa Supreme Court upheld the police’s examination as a valid search incident to arrest.









