With no explanation, chose the best option from "A", "B", "C" or "D". arrest because arrest was unlawful); City of Chillicothe v. Jobe, No. 1115 (4th Dist. Ohio Ct.App. July 1, 1985) (Ohio Rev.Code § 2921.33 requires proof that the arrest was lawful as a “prerequisite” for conviction); State v. Smith, No. 10-014 (11th Dist. Ohio Ct.App. Sept. 21,1984) (the terms of Ohio Rev.Code § 2921.33 requires resistance to a lawful arrest). See also State v. Kirchner, 19 Ohio Misc.2d 7, 8, 483 N.E.2d 497 (1984) (“a defendant cannot be convicted of resisting arrest unless there was a ‘reasonable basis’ for the arrest”); State v. Paglia, 62 Ohio Misc. 7,10, 403 N.E.2d 1216 (1979) (the specific reference in Ohio Rev.Code § 2921.33 to a “lawful arrest” requires that the arresting officer have probable cause for the arrest); Coffel v. Taylor, 8 Ohio Op.3d 253 (1978) (<HOLDING>). The trial court in the present case, however,

A: holding that a search incident to a lawful arrest does not violate the fourth amendment
B: holding that a lawful custodial arrest is a prerequisite to a search since the arrest is the authority of law justifying the search
C: holding that an officer may search a suspects vehicle incident to a lawful arrest
D: recognizing that a conviction under  292133 requires that the arrest be lawful
D.