MD: DUI stop and arrest permits search incident for source of intoxication

“Under Arizona v. Gant, 556 U.S. 332 (2009), when a police officer validly arrests a motorist for driving under the influence of alcohol, in the absence of facts indicating otherwise, the officer, based on his or her knowledge and experience, may reasonably conclude that open containers or other evidence bearing on the DUI offense may be present in the passenger compartment of the vehicle and conduct a search for such evidence, even though the defendant has been safely secured and has no access to the vehicle.” Taylor v. State, 2016 Md. LEXIS 292 (May 23, 2016)