Decided March 23, 1964
Preston (and some other guys) were arrested for vagrancy when they were contacted by police at 3 am for loitering in a car in a business district since 10 pm. They were searched and transported to the station, and the car (which hadn't been searched) was driven to the station and then towed. Later, the car was searched which uncovered evidence that was later used to convict Preston & Co. of conspiracy to rob a bank. The government sought to justify the search of the car as being incident to arrest, but the Supreme Court overturned the conviction because the search was not contemporaneous (either in time or place) with the arrest.