TX: Search incident still justified by discovery of a different offense after arrest

The court of appeals erred in holding that a search incident to arrest could not be justified by discovery of a different offense after arrest. As long as there was probable cause to arrest for the newly-discovered offense, and the search occurred close in time to the defendant’s formal arrest, an officer may conduct a search incident to arrest on the basis of an offense discovered after formal arrest for a different crime. State v. Sanchez, 2017 Tex. Crim. App. LEXIS 944 (Sept. 27, 2017), rev’g 501 S.W.3d 165, 167 (Tex. App.—Corpus Christi-Edinburg 2016) cited in § 22.08 n.16.1.