With respect to the search-incident-to-arrest exception to the warrant requirement of the Fourth Amendment to the United States Constitution, this Court held in Arizona v. Gant that the exception applies only if the container searched is within the arrestee's reach at the time of the search. Does Gant's limitation on the geographic scope of the exception apply to searches of containers found in buildings, or only to containers found in automobiles?

Whether the search-incident-to-arrest exception from Arizona v. Gant applies to searches of containers in buildings or only in automobiles