Missouri Court of Appeals, Eastern District / Date unavailable
State of Missouri, Respondent, v. Patricia Boehmer, Appellant.
Patricia Boehmer appealed her conviction for possession of a controlled substance, arguing the trial court erred in denying her motion to suppress evidence seized during a warrantless search. Boehmer contended the search was not incident to an arrest because officers did not formally arrest or handcuff her before the search. The appellate court affirmed, holding that under the totality of the circumstances, Boehmer was under arrest when the search occurred, as officers had taken control of her movements and informed her she would be booked.