Court of Appeals of Washington September 20, 2002, No. 28032-9-II (State v. Clausen)

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United States · · · 20-09-2002

Armstrong, J.

— Brian Clay Clausen appeals the denial of his suppression motion. He argues that the search of his vehicle was not a valid search incident to custodial arrest *659because he was initially arrested on a misdemeanor driving charge and the county jail was not booking people on such charges due to jail overcrowding. Finding that Clausen’s arrest was a custodial arrest, we affirm.

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