With no explanation, chose the best option from "A", "B", "C" or "D". 161 (Mo.1969) ; for “Thus the Government is obliged to justify the arrest by the search and at the same time to justify the search by the arrest. This will not do. * * * Any other rule would undermine ‘the right of the people to be secure in their persons, houses, papers and effects’, and would obliterate one of the most fundamental distinctions between our form of government, where officers are under the law, and the police-state where they are the law.” Johnson v. United States, 333 U.S. 10, 16-17, 68 S.Ct. 367, 370, 92 L.Ed. 436. More to the point in the instant case are the following decisions: State v. Michaels (1963) 60 Wash.2d 638, 374 P.2d 989 (arrest for failing to signal left turn did not warrant search in trunk for suitcases); Lane v. Commonwealth (Ky.1964) 386 S.W.2d 743 (<HOLDING>); McCurdy v. State (1965) 42 Ala.App. 646, 176

A: holding an arrest for improper passing a mere pretext for searching trunk containing seven cases of whiskey
B: holding a defendants response to even an invalid arrest  may constitute independent grounds for arrest
C: holding that the answer to the question of what police must do before searching a cell phone seized incident to an arrest is accordingly simple get a warrant
D: holding that inconsistency in employers reasons for the termination is an indication of pretext
A.