People v. Cregan 

Defendant was convicted, after stipulated bench trial, of unlawful possession of controlled substance (cocaine), which was found in hair gel container, inside his luggage which police searched after arresting him at train station. Police had received a tip that Defendant, who had a civil warrant for child support, would be traveling by train. Defendant dropped his luggage, upon officers' order, and was then handcuffed. Defendant was within arms' reach of luggage, though handcuffed prior to search, and luggage was not locked. Officers knew Defendant to be a gang member and were concerned he might have dangerous weapon. Search was reasonable and valid incident to Defendant's arrest. (STEIGMANN and POPE, concurring.)