As the circuit court observed, this was not merely a Terry stop; rather, it was a search incident to a lawful arrest, which is a well-established exception to the limitation under Terry. People v. McKinney, 274 Ill. App. 3d 880, 888 (1995). Adamski's search incident to arrest required no additional justification, and could be for purposes of not only officer safety, but to discover other items used in commission of a crime.

¶ 25 The right to conduct a warrantless search incident to a lawful arrest is a well-established exception to the limitation under Terry. People v. McKinney, 274 Ill. App. 3d 880, 888 (1995). A custodial arrest of a suspect based upon probable cause is "a reasonable intrusion under the Fourth Amendment [and] that intrusion being lawful, a search incident to the arrest requires no additional justification."

Accordingly, cases applying subsection 108-1(1) do so under the assumption that it acts to enable police and not to add to any prohibitions on their conduct. See People v. Seymour, 84 Ill. 2d 24, 33 (1981) ("The right to search a person incident to a lawful arrest * * * does not * * * depend solely upon the provisions of our statute"); People v. Pickett, 39 Ill. 2d 88, 96 (1968) ("we do not believe the search was unreasonable and conclude that the trial court did not interpret section 108-1(d) as permitting an unreasonable search"); People v. McKinney, 274 Ill. App. 3d 880, 889 (1995) (declaring, just after quoting section 108-1, tha t "[p]olice officers have broad statutory authority to conduct a search once they have effected a lawful arrest"); People v. Zeller, 51 Ill. App. 3d 935, 939 (1977) ("Section 108-1 * * * authorizes the search of an arrestee for a variety of reasons, including to protect the officer from attack"). We say that the legislature's attempt to codify the search-incident-to-arrest exception to the warrant requirement is ineffectual because it purports to grant power to police, yet any power such a statute may grant police must yield to constitutional protection afforded against it.

Moreover, the fact that an officer other than the arresting officer conducted the search does not make the search unconstitutional. People v. McKinney, 274 Ill. App.3d 880, 889 (1995) (a search incident to an arrest may be conducted at the police station by an officer other than the arresting officer). Defendant does not dispute the fact that the booking officer noticed the coffee filters in defendant's purse prior to beginning an official inventory of defendant's possessions.

A trial court's ruling on a motion to suppress will not be reversed unless it is manifestly erroneous. People v. McKinney, 274 Ill. App.3d 880, 888, 655 N.E.2d 40, 45 (1995). Section 112-4(b) of the Code of Criminal Procedure of 1963 provides in pertinent part: