People v. Tripp 

(Court opinion corrected 3/8/11.) Defendant was convicted of armed robbery after jury trial, and court properly denied him leave to file a successive postconviction petition. U.S. Supreme Court's Gant v. Arizona decision, which was nine years after initial postconviction petition, is an objective factor that impeded Defendant's ability to raise the issue during the first petition. Gant case introduced a new rule as to already-existing limitations on officers when conducting search incident to arrest, but not a watershed rule requiring retroactive application to cases on collateral review. Gant rule is that search incident to arrest is lawful only if the arrestee is within reaching distance of passenger compartment at time of search or if reasonable to believe that vehicle contains evidence of offense of arrest. (GALLAGHER and PUCINSKI, concurring.)