Read the following excerpt from a US court opinion:
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cannot be materially distinguished. The officers initiated the search of this automobile without consent or probable cause. Only under the proper circumstances may an automobile be validly searched as a search incident to arrest. Miller v. State, 373 So.2d 1004, 1006 (Miss.1979). This ease did not present the proper circumstances constituting a valid search incident to arrest. Without relying on hindsight, the analysis does reach the point where the officers allegedly smelled marijuana since they were unlawfully in the automobile in the first place. Townsend was away from the car when arrested, and the car was closed up for towing. He had no access whatsoever to the car at the time of the search. See New York v. Belton, 453 U.S. 454, 461, 101 S.Ct. 2860, 2864-65, 69 L.Ed.2d 768 (1981) . The majority has essentially looked at the
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What is the most suitable continuation to the opinion? Your options are:
A. holding that after making an arrest of the driver of a vehicle the police may search the passenger compartment of the vehicle
B. holding that search of golf bag was not legal as search incident to arrest because it was not in passenger compartment of vehicle or otherwise within arrestees immediate control
C. recognizing that permissive search of car compartment incident to arrest is based on the fact that compartment is within reach of the arrestee
D. holding police incident to arrest of occupant of automobile may search entire passenger compartment of vehicle
E. holding that although search of passenger compartment was legal search of trunk was not
Reply with [A, B, C, D, E] only.