Gutierrez-Moran v. United States

How later courts describe this case

• concluding that vehicle search was not a contemporaneous search incident to arrest, because search occurred after police brought car to police station, and while defendants were inside police station
• stating that federal common law recognizes two different marital privileges
• “This search occurred after the car was moved, the defendants were inside the police station, and the police decided to have the car towed. The search cannot be described as contemporaneous to the arrest.”