Court of Appeals of Washington February 4, 2008, No. 58463-4-I (State v. Bello)

*932¶1 — Article I, section 7 of the Washington State Constitution1 prohibits the police from performing warrantless searches of items that the officers know or should know are the personal effects of a vehicle occupant incident to the arrest of a different vehicle occupant, unless those personal effects were in the immediate control of the arrested person prior to the arrest. State v.