SANDSTROM, Justice.
[¶ 1] Claude Joseph Mercier appeals after he pled guilty to possession of methamphetamine and possession of drug paraphernalia, reserving the right to appeal the [482]*482denial of his motion to suppress evidence. Because the district court properly denied the motion to suppress, we affirm the criminal judgment.
I
[¶ 2] According to testimony at the suppression hearing, at around 11 p.m. on May 4, 2015, Bismarck Police Officer April McCarthy was dispatched to an area for a report of suspicious activity. The identified caller described the suspect as a white male wearing a black t-shirt, and believed this suspect and a female individual were trying to rob him. When Officer McCarthy arrived near the scene, she observed a male who matched the description given, later identified as Mercier, near the location indicated by the caller. She got out of her vehicle and asked Mercier for identification, which he said was in his backpack at a house across the street. When asked for his name, Mercier identified himself as “Dewayne Liggins” with a birth date of March 29, 1989, then as “Dewayne Lig-gins” with a birth date of March 2, 1989, and then again as the same individual but from South Dakota. Each time Officer McCarthy attempted to run this information through dispatch, it came back negative, or not on file.
[¶ 3] While Officer McCarthy was attempting to identify Mercier, Bismarck Police Officers Swenson and Bratsch also arrived on the scene. Officer Swenson came to the scene because he recognized the name Dewayne Liggins when he heard it over the radio. Swenson informed McCarthy that he had known a Dewayne Liggins previously and that he was an African-American male. When Mercier informed the officers his backpack containing his identification was across the street, the officers asked him whether they could “go get the backpack.” Mercier gave the officers a description of the backpack, and when Officer Bratsch went to retrieve the described backpack, someone at the house told him “this is C.J.’s.” The name differed from the one Mercier had been giving the officers. The record is silent as to whether the backpack was retrieved from inside or outside the house where Mercier said it was located. Upon Officer Bratsch’s return with the backpack, Mercier confirmed it was his. He declined to allow the officers to search the backpack themselves, but was allowed to go through it slowly himself to obtain his identification. When asked whether there were any weapons in the backpack, Mercier replied there was a knife. The officers then placed Mercier in handcuffs for safety purposes and searched him. While searching him, Officer Bratsch pulled Mercier’s wallet out of his pocket and found it contained two identification cards, one belonging to Claude Mercier and one to Dwayne Liggins, as well as some marijuana.. After running the correct name and date of birth through dispatch, the officers discovered Mercier had active warrants for his arrest. He was arrested, placed in the back of a squad car, and read his Miranda, rights. The officers searched Mercier’s backpack, finding several items that had been reported stolen as well as methamphetamine and drug paraphernalia. Mercier was initially arrested and held on possession of stolen property, possession of marijuana, false information to law enforcement, two counts of possession of drug paraphernalia, and ingestion of a controlled substance.
[¶ 4] After Mercier was formally charged with possession of drug paraphernalia and possession of methamphetamine, he moved to suppress evidence, claiming the police officers’ questioning of him and searches of his backpack and wallet were illegal searches and seizures in violation of the Fourth Amendment. After a hearing, the district court denied the motion. Mer-[483]*483cier conditionally pled guilty to the charges.
[¶ 5] The district court had jurisdiction under N.D. Const, art. VI, § 8, and N.D.C.C. § 27-05-06. The appeal was timely under N.D.R.App.P. 4(b), and this Court has jurisdiction under N.D. Const, art. VI, §§ 2, 6, and N.D.C.C. § 29-28-06.
II
[¶ 6] On appeal, Mercier argues the police questioning of him and searches of his backpack and wallet were illegal searches and seizures in violation of the Fourth Amendment.
[¶ 7] This Court applies a deferential standard of review when reviewing a district court decision on a motion to suppress:
The trial court’s disposition of a motion to suppress will not be reversed if, after conflicts in the testimony are resolved in favor of affirmance, there is sufficient competent evidence fairly capable of supporting the trial court’s findings, and the decision is not contrary to the manifest weight of the evidence. That standard of review recognizes the importance of the trial court’s opportunity to observe the witnesses and assess their credibility, and we “accord great deference to its decision in suppression matters.”
State v. Sabinash, 1998 ND 32, ¶ 8, 574 N.W.2d 827 (citations omitted).
■ [¶ 8] “In the context of law enforcement-citizen contacts, a ‘Terry’ stop, or investigative stop, temporarily restrains an individual’s freedom, which results in a Fourth Amendment seizure.”. State v. Boyd, 2002 ND 203, ¶ 13, 654 N.W.2d 392 (citing State v. Glaesman, 545 N.W.2d 178, 182 (N.D.1996)). “Within the meaning of the Fourth Amendment, a seizure occurs whenever an officer stops an individual and restrains his freedom.” Terry v. Ohio, 392 U.S. 1, 16, 88 S.Ct. 1868, 20 L.Ed.2d 889 (1968). “Terry created a limited exception to this general rule: certain seizures are justifiable under the Fourth Amendment if there is articulable suspicion that a person has committed or is about to commit a crime.” Florida v. Royer, 460 U.S. 491, 498, 103 S.Ct. 1319, 75 L.Ed.2d 229 (1983). See also Glaesman, 545 N.W.2d at 182 (citations omitted) (“An investigative stop must be ‘justified by some objective manifestation that the person stopped is, or is about to be, engaged in criminal activity.’ ”).
[¶ 9] In applying the Supreme Court’s decision in Terry, we have said that in reviewing a Terry stop, a court must “(1) determine whether the facts warranted the intrusion of the individual’s Fourth Amendment rights, and if so, (2) determine whether the scope of the intrusion was reasonably related to the circumstances which justified the interference in the first place.” State v. Sarhegyi, 492 N.W.2d 284, 286 (N.D.1992). “We use an objective standard: would a reasonable person in the officer’s position be justified by some objective evidence in believing the defendant was, or was about to. be, engaged in unlawful activity?” State v. Boyd, 2002 ND 203, ¶ 14, 654 N.W.2d 392 (citing State v. Indvik, 382 N.W.2d 623, 627 (N.D.1986)).
[¶ 10] To determine whether an officer has-'a reasonable and articulable suspicion, we 'examine the-.information known to the officer at the time of the stop. State v. Robertsdahl, 512 N.W.2d 427, 428 (N.D.1994) (citing State v. Miller, 510 N.W.2d 638 (N.D.1994)). The reasonable-and-articulable-suspicion standard requires that the officer justify the stop “with more than just a vague ‘hunch’ or other non-objective facts; and ... the ar-ticulable facts must produce, by reasonable [484]*484inference, a reasonable suspicion of unlawful conduct.” Bryl v. Backes, 477 N,W.2d 809, 811 n. 2 (N.D.1991) (quoting State v. VandeHoven, 388 N.W.2d 857, 858 n. 1 (N.D.1986)). In Geiger v. Backes, 444 N.W.2d 692, 693 (N.D.1989), this Court noted law-enforcement officers do not have to analyze the individual factors of a case in a vacuum.- They also are not required “to point to a single factor which, standing alone, signals a potential violation of the law. Rather, officers are to assess the situation as it unfolds and, based upon inferences and deductions drawn from their experience and training, make the determination whether all of the circumstances viewed together create a reasonable suspicion of potential criminal activity.” Id.
[¶ 11] Here Mercier argues he was seized, for purposes of the Fourth Amendment, prior to the officers’ development of reasonable suspicion. He claims he was seized during his initial encounter with Officer McCarthy when she stopped him and asked him for identification. The State argues Mercier was not seized during his initial encounter with Officer McCarthy.
[1112] Not all encounters between law enforcement officers and citizens .’constitute “seizures” implicating the Fourth Amendment. City of Jamestown v. Jerome, 2002 ND 34, ¶ 5, 639 N.W.2d 478. “It is not a Fourth Amendment seizure for a police -officer to approach ,and talk with a person in a public place....” State v. Leher, 2002 ND 171, ¶ 7, 653 N.W.2d 56. A police officer’s “approach ... is not a seizure if the officer inquires ... in a conversational manner, does not order the person to do- something, and does not demand a response.” State v. Langseth, 492 N.W.2d 298, 300 (N.D.1992). A casual encounter between an officer and a citizen can become a seizure if “a reasonable person would view the officer’s actions — if done by another private citizen— as threatening or offensive.” State v. Boyd, 2002 ND 203, ¶ 7, 654 N.W.2d 392. A seizure occurs only when “the officer, by means of physical force or show of authority, has in some way restrained the liberty of a citizen.” Sayler v. North Dakota Dep’t of Transp., 2007 ND 165, ¶ 18, 740 N.W.2d 94.
[¶ 13] In this case, Officer McCarthy did not need reasonable suspicion simply to approach Mercier and speak with him in a conversational manner. The issue is whether McCarthy escalated the casual encounter into a seizure by ordering Mercier “to do something, by demanding a response, or by threatening [him] with a show of authority or command,” and if so, whether she had reasonable suspicion to order him to stop and identify himself. City of Jamestown v. Jerome, 2002 ND 34, ¶ 9, 639 N.W.2d 478. This Court has held: “If ... an officer directs a citizen to exit a parked vehicle, or otherwise orders a citizen to do something, then the officer has arguably made a stop which, consistent with the Fourth Amendment rights of the citizen, requires the officer to have a reasonable and articulable suspicion that person has been or is violating the law.” State v. Leher, 2002 ND 171, ¶¶ 7, 10, 653 N.W.2d 56.
[¶ 14] Under N.D.C.C. § 29-29-21 (emphasis added):
A peace officer may stop any person abroad in a public place whom the officer reasonably suspects is committing, has committed, or is about to commit:
(1) Any felony.'
(2) A misdemeanor relating to the possession of a concealed or dangerous weapon or weapons.
(3) Burglary or unlawful entry..
[485]*485(4) A violation of any provision relating to possession-of marijuana or of narcotic, hallucinogenic, depressant, or stimulant drugs.
The peace officer may demand of such person the person’s name, address, and an explanation of the person’s actions ....
[¶15] Here the initial contact between Officer McCarthy and Mercier occurred when McCarthy approached Mercier for the purpose of having him identify himself because he matched the physical description of a suspicious person recently reported in the area. Under this Court’s case law, a simple request made by McCarthy for Mercier to identify himself would not be a seizure for purposes of the Fourth Amendment. A command to do so, however, would be. See State v. Leher, 2002 ND 171, ¶¶ 7, 10, 653 N.W.2d 56.
[¶ 16] Officer McCarthy testified at the suppression hearing regarding her initial encounter with Mercier. She testified she got out of her vehicle to speak with him and -asked him for his identification card or some sort of identification. Mercier informed McCarthy that his identification was in his backpack at a house across the street. When asked if she specifically told Mercier whether or not he was free to leave, McCarthy stated that “the only thing I told him was that once I identify him and he came up where he didn’t have any kind of warrants, he was going to be cut loose as long as he wasn’t involved in this investigation.” We believe a reasonable person in Mercier’s'position would not feel free to leave at that moment until he or she provided identification. Officer McCarthy was ordering Mercier to do something (provide identification), and told Mercier he would be “cut loose” as soon as he did so. This is an order to do something which, consistent with the Fourth Amendment rights of the citizen, “requires the officer to have a reasonable .and articu-lable suspicion that person has been or is violating the law.” Leher, 2002 ND 171, ¶¶ 7, 10, 653 N.W.2d 56.
[¶ 17] We conclude Officer McCarthy did have a reasonable suspicion Mercier was, or was about to be, engaged in criminal activity. While normally his action of simply walking on the street would not suggest criminality, when paired with the information known to Officer McCarthy at the time, his actions could give rise to reasonable suspicion. The United States Supreme Court has held that in evaluating the validity of an investigatory stop to determine whether there was.reasonable suspicion of criminal activity, courts must consider the totality of the circumstances. United States v. Sokolow, 490 U.S. 1, 8, 109 S.Ct. 1581, 104 L.Ed.2d 1 (1989). The Court stated:
Any one of these factors is not by itself proof of any illegal conduct and is quite consistent with innocent travel. But we think taken together they amount to reasonable suspicion.... We said in, Reid v. Georgia, 448 U.S. 438, 100 S.Ct. 2752, 65 L.Ed.2d 890 (1980) (per curiam), “there could, of course, be circumstances in which wholly lawful conduct might justify the suspicion that criminal activity was afoot.” Id. at 441, 100 S.Ct. at 2754. Indeed, Terry itself involved “a series of acts, each of them perhaps innocent” if viewed separately, “but which taken together warranted further investigation.”
Sokolow, 490 U.S. at 9-10, 109 S.Ct. 1581. The facts in this case, when viewed in their totality through the eyes of a trained law enforcement officer, are sufficient to give rise to a reasonable suspicion of unlawful activity. Mercier matched the description of a suspicious person reported to the police, and he was in the location reported to the police late at night when few other [486]*486people would be out. Additionally, when he did comply and provide information regarding his identity to the officers, it was clear he was providing false information, because nothing he provided came back as valid. Therefore, while Mercier was “seized” for purposes of the Fourth Amendment, the seizure was reasonable and valid under the circumstances of this case. The district court did not err in finding the seizure to be valid.1
Ill
[¶ 18] Mercier also argues the searches of both his wallet and backpack were unlawful under the Fourth Amendment. The State argues these searches were valid exceptions to the warrant requirement as searches incident to a lawful arrest.
[¶ 19] Under the Fourth Amendment of the United States Constitution:
The right of the people to be secure in their persons, houses, papers and effects, against unreasonable searches and seizures, shall not be violated; and no warrants shall issue but upon probable cause, supported by oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized.
The North Dakota Constitution similarly prohibits unreasonable searches and seizures. See N.D. Const, art. I, § 8.
[1120] The United States Supreme Court has held “searches conducted outside the judicial process, without prior approval by judge or magistrate, are per se unreasonable under the Fourth Amendment — subject only to a few specifically established and well-delineated exceptions.” Katz v. United States, 389 U.S. 347, 357, 88 S.Ct. 507, 19 L.Ed.2d 576 (1967) (footnote omitted). A search incident to a lawful arrest is one such exception. Weeks v. United States, 232 U.S. 383, 392, 34 S.Ct. 341, 58 L.Ed. 652 (1914). We have held that “[a] search incident to arrest is justified because ‘[a] custodial arrest of a suspect based on probable cause is a reasonable intrusion under the Fourth Amendment; that intrusion being lawful, a search incident to the arrest requires no additional justification ... [i]t is the fact of the lawful arrest which establishes the authority to search.’ ” State v. Overby, 1999 ND 47, ¶ 7, 590 N.W.2d 703 (quoting United States v. Robinson, 414 U.S. 218, 235, 94 S.Ct. 467, 38 L.Ed.2d 427 (1973)).
[¶ 21] The United States Supreme Court has also held that so long as probable cause to arrest exists before the search, and the arrest is substantially contemporaneous, a warrantless search preceding arrest is ■ reasonable under the Fourth Amendment. See Rawlings v. Kentucky, 448 U.S. 98, 111, 111 n. 6, 100 S.Ct. 2556, 65 L.Ed.2d 633 (1980) (“Where the formal arrest followed quickly on the heels of the challenged search of petitioner’s person, we do not believe it particularly important that the search preceded the arrest, rather than vice versa,” so long as the fruits of the search were “not necessary to support probable cause to arrest.”).
[¶ 22] Under the Rawlings search incident to arrest rationale, Officer Bertsch’s search of Mercier was reason[487]*487able if (1) Bertsch had probable cause to arrest Mercier before searching him; and (2) the arrest was substantially contemporaneous to the search. Id. Mercier claims the search of his wallet was an illegal pat-down search because the officer knew it was a wallet and had no reason to believe it was a dangerous weapon. The Supreme Court has held, ‘‘[I]t is reasonable for the arresting officer to search the person arrested in order to remove any weapons that the latter might seek to use in order to resist arrest or effect his escape.... In addition, it is entirely reasonable for the arresting officer to search for and seize any evidence on the arrestee’s person in order to prevent its concealment or destruction.” Chimel v. California, 395 U.S. 752, 763, 89 S.Ct. 2034, 23 L.Ed.2d 685 (1969). Similarly, in United States v. Robinson, 414 U.S. 218, 236, 94 S.Ct. 467, 38 L.Ed.2d 427 (1973), the Court noted, “Having in the course, of a lawful search come upon the crumpled package of cigarettes, [the officer] was entitled to inspect it.”
[¶ 23] Here the officers searched Mercier when he said there was a knife in his backpack while he was rifling through it to find his identification; This search was subsequent to his being handcuffed, but prior to his being placed formally under arrest. While a warrantless search prior to formal arrest should be the exception to the ordinary practice of a search following arrest, the facts of this case demonstrate that the officers had probable cause to arrest Mercier, even absent any of the evidence obtained during the pre-arrest search. At the time Mercier was placed in handcuffs and his wallet was searched, the officers already knew he was not the person he was • claiming to be. Officer Swenson specifically knew who Dwayne Liggins was and knew he was African-American, which Mercier was not. Although his formal arrest occurred after the search, this does not invalidate the search since the officers already had probable cause to arrest him for giving them false information ■ regarding his identity. See N.D.C.C. § 12.1-11-03(1). Mercier also was arrested within minutes of being searched. Therefore, the officer’s search of Mercier’s wallet was valid under the search incident to arrest exception to the warrant requirement.
IV
■ [1124] Mercier argues the officers unlawfully searched his backpack. He claims he had a reasonable expectation of privacy in the backpack and the officers were required to obtain a warrant to search it, even after his arrest. He argues the backpack was not within his immediate control and therefore the search of it violated the Fourth Amendment.
[¶ 25] Mercier relies on Arizona v. Gant, 556 U.S. 332, 129 S.Ct. 1710, 173 L.Ed.2d 485 (2009), an automobile-search case, arguing the .search of his backpack did not qualify for the search-incident-to-arrest exception to the warrant requirement because, at the, time of the search, he was handcuffed in the. back of a squad car. Both Mercier and the State agree that a backpack is not an automobile. The State argues a backpack is closer to a purse than to an automobile,_ and cites to cases such as State v. Woinaromcz, 2006 ND 179, 720 N.W.2d 635, holding that a purse may be searched incident to an arrest. Many of the search-incident-to-an-arrest cases relate to automobile searches and residence searches. Fewer relate to searches untethered to either.
■ [¶ 26] Recently, in Birchfield v. North Dakota, 579 U.S. -, 136 S.Ct. 2160, 2175, 195 L.Ed.2d. 560 (2016), the Supreme Court said:
One Fourth Amendment historian has observed that, prior to American inde[488]*488pendence, “[ajnyone arrested could expect that not, only his surface clothing but his body, luggage, and saddlebags would be searched and, perhaps, his shoes, socks, and mouth as well.” W. Cuddihy, The Fourth Amendment: Origins and Original Meaning: 602-1791, p, 420(2009).
No historical evidence suggests that the Fourth Amendment altered the permissible bounds of arrestee searches....
[¶27] The United States Supreme Court, in a home-search-incident-to-an-arrest case, Chimel v. California, 395 U.S. 752, 763, 89 S.Ct, 2034, 23 L.Ed.2d 685 (1969), held that an officer making a lawful custodial arrest may search the arrestee and the area within the arrestee’s imrríédiate control. Four years after Chimel, the Supreme Court held a search incident to arrest permitted the search of a closed container' found on the arrestee during a search incident to arrest. United States v. Robinson, 414 U.S. 218, 94 S.Ct. 467, 38 L.Ed.2d 427 (1973). The Robinson Court held:
A police officer’s determination as to how and where to search the person of a suspect whom he has arrested is necessarily a quick ad hoé judgment' which' the Fourth Amendment does not require to be broken down in each instance into an analysis of each step in the search. The authority to search the person incident to a lawful custodial arrest, while based upon the need to disarm and to discover evidence, does not depend on what a court may later decide was the probability in a particular arrest situation that weapons or evidence would in fact be found upon the person of the suspect. • A custodial arrest of a suspect based on probable cause is a reasonable intrusion under, the Fourth Amendment; that intrusion being lawful, a search incident to the arrest requires no additional justification. It is the fact of the lawful arrest which establishes the authority to search, and we hold that in the case of a lawful custodial arrest a full search of the. person is not only an exception to the warrant requirement of the Fourth Amendment, but is also a-“reasonable” search under that Amendment.
Id. at 235, 94 S.Ct. 467.
[¶ 28] In Robinson, an automobile-search-incident-to-an-arrest case, the Supreme Court identified different types of searches incident to a defendant’s arrest: a search of the arrestee himself, and a search of the area within the arrestee’s immediate control. See United States v. Robinson, 414 U.S. 218, 224, 94 S.Ct. 467, 38 L.Ed.2d 427 (1973) (“This general exception has historically been -formulated into two distinct propositions. The first is that a Search may be made of the person of the' arrestee by virtue' of the lawful arrest: The second is that a search may be made of the area within the control of the arrestee.”).
[¶ 29] Regarding a search of the arrestee himself, the Supreme Court cited its long line of cases dating back to Weeks v. United States, 232 U.S. 383, 34 S.Ct. 341, 58 L.Ed. 652 (1914),.concluding that a search of the arrestee, including clothing and personal effects, requires “no additional justification” beyond the lawful custodial arrest. Robinson, 414 U.S. at 224-226, 235, 94 S.Ct. 467. A search of the arrestee is justified by the need to disarm the individual and to discover evidence, but the search need not be justified by probable cause to search for weapons or, .evidence. Id. It is “not only- an exception to the .warrant requirement of the Fourth Amendment, but is also a ‘reasonable’ search under that Amendment.” Id. at 235, 94 S.Ct. 467. A, search of the arrestee, therefore, requires “no additional [489]*489justification” beyond the fact of the lawful custodial arrest. Id,
[¶30] In Arizona v. Gant, 556 U.S. 332, 129 S.Ct. 1710, 173 L.Ed.2d 485 (2009), the Supreme Court addressed this issue as applied to vehicles, and clarified its previous holding in New York v. Belton, 453 U.S. 454, 101 S.Ct. 2860, 69 L.Ed.2d 768 (1981). Belton had been “widely understood to allow a vehicle search incident to the arrest of a recent occupant even if there [was] no possibility the arrestée could gain access to the vehicle at the time of the search.” Gant, 556 U.S. at 341, 129 S.Ct. 1710. The Gant Court held that searches of the area within an arrestee’s immediate control, including the interior of a vehicle, must be supported by some additional justification of officer safety or evidence preservation, beyond the fact of the lawful arrest. Id. at 339, 129 S.Ct. 1710. See also id. at 351, 129 S.Ct. 1710 (“Police may search a vehicle incident to a recent occupant’s arrest only if the arrestee is within reaching distance of the passenger compartment at the time of the search or it is reasonable to believe the vehicle contains evidence of the offense of arrest.”).
[¶ 31] The Court’s decision in Gant clarified and limited the “area within the immediate control” type of' automobile-search incident to arrest. Nothing in the Court’s opinion in Gant, however, suggested it was meant to limit or abrogate the Robinson holding of a search of the arres-tee incident to arrest. The Supreme Court has continued to cite the Robinson holding allowing a full search of the arres-tee incident to arrest with no additional justification other than the lawful arrest. In Maryland v. King, — U.S. -, 133 S.Ct. 1958, 1970-71, 186 L.Ed.2d 1 (2013), for example, the Court stated:
Also uncontested is the “right on the part of the government, always recognized under English and -American law, to search the person of the accused when legally arrested.” Weeks v. United States, 232 U.S. 383, 392, 34 S.Ct. 341, 58 L.Ed. 652 (1914), overruled on other grounds, Mapp v. Ohio, 367 U.S. 643, 81 S.Ct. 1684, 6 L,Ed.2d 1081(1961). “The validity of the search of a person incident to a lawful arrest has been regarded as settled from its first enunciation, and has remained virtually unchallenged.” United States v. Robinson, 414 U.S. 218, 224, 94 S.Ct. 467, 38 L.Ed.2d 427 (1973). Even in that context, the Court has been clear, that individual suspicion is not necessary, because “[t]he constitutionality of a search incident to an arrest does not depend on whether there is any indication that the person arrested possesses weapons or evidence. The fact of a lawful arrest, standing alone, authorizes a search.” Michigan v. DeFillippo, 443 U.S. 31, 35, 99 S.Ct. 2627, 61 L.Ed.2d 343 (1979).
[¶32] In King, the Supreme Court held “the need for law enforcement officers iñ a safe and accurate way to process and- identify the persons and possessions they must take into custody” outweighed an arrestee’s privacy interest in his own DNA. King, 133 S.Ct. at 1970 (emphasis added). As explained further in United States v. Matthews, 532 Fed.Appx. 211, 223 (3d Cir.2013):
[C]ertainly if the government’s interest in correctly identifying a person taken into custody outweighs that person’s expectation of privacy in,his or her own DNA, the government’s interest in ensuring officer safety while transporting an arrested person’s luggage outweighs that person’s expectation of privacy in such luggage (which would be subject to a search as soon as the person arrived at the cell block, in any event).
[¶ 33] In analyzing the search of an arrestee, therefore, we follow the Su[490]*490preme Court’s rationale that “a search may be made of the person of the arrestee by virtue of the lawful arrest.” United States v. Robinson, 414 U.S. 218, 224, 94 S.Ct. 467, 38 L.Ed.2d 427 (1973). Because the Supreme Court’s decision in Gant does not restrict the lawful search of an arres-tee, there is no requirement that the arres-tee be within reaching distance or have the item within his immediate control once it is seized as part of the lawful arrest.
[¶ 34] To determine whether a particular personal item should be considered part of the arrestee-, including his personal effects, rather than it simply existing in the arrestee’s surroundirig area, courts have said it “turns on whether the arrestee had ‘actual and exclusive possession at or immediately preceding the time of arrest.’” State v. Brock, 184 Wash.2d 148, ¶ 12, 365 P.3d 1118 (2016) (quoting State v. Byrd, 178 Wash.2d 611, 623, 310 P.3d 793 (2013)). See also People v. Cregan, 2014 IL 113600, ¶ 50, 381 Ill.Dec. 693, 10 N.E.3d 1196 (“The true measure of whether an object, whether it is a cigarette pack or a suitcase, is ‘immediately associated’ with an arrestee is whether he is in actual physical possession of the object at the time of his arrest.”).
[¶ 35] In State v. Brock, 184 Wash.2d 148, ¶ 12, 355 P.3d 1118 (2015), the Supreme Court of Washington addressed this issue as well as the scope of the language “immediately preceding arrest.” In that case, with very similar facts to ours, the defendant, Antoine Brock, was carrying his backpack when an officer approached him at a public park. During the course of his investigation, the officer eventually took the backpack from Brock for safety purposes and placed it in the passenger seat of his patrol vehicle. Id. at ¶¶ 3-4. After discovering Brock was providing false information to him regarding his identity, the officer placed Brock under arrest and searched the backpack. Id. at ¶5. In the backpack, the officer found Brock’s wallet, which contained various drugs as well as an identification card. Id. at ¶ 6. After running the name on the card through dispatch, the officer discovered Brock had an active felony warrant for his arrest. Id. at ¶ 7. The officer then emptied the contents of the backpack before taking Brock into custody, discovering several items indicative of identity theft and forgery, as well as more drugs. Id.
[¶ 36] At; trial; Brock conditionally plead guilty to 10 counts of identity theft, 3 counts of forgery, and violation of the Uniform Controlled Substances Act, reserving the right to appeal the trial court’s suppression ruling. Id. at ¶ 8. On . appeal, Brock argued the officer’s search of his backpack was not a valid search of “his person,” because he did not have actual exclusive possession of the backpack immediately preceding arrest, since the officer had placed the backpack in his patrol car and Brock was not holding it when he was arrested. State v. Brock, 182 Wash.App. 680, ¶ 17, 330 P.3d 236.. The Court of Appeals of Washington agreed and reversed Brock’s conviction. Id. at 689, 330 P.3d 236. On appeal, the Supreme Court of Washington reversed the decision of the Court of Appeals and held the backpack was part of “the defendant’s person” at the time of arrest, despite the fact he was not still wearing the backpack at the time of the formal arrest. State v. Brock, 184 Wash.2d 148, 355 P.3d 1118 (2015).
[¶ 37] In reaching this result, the court noted that the underlying justification for an item being considered “part of the person” is that “there are presumptive safety and evidence preservation concerns associated with police taking custody of those personal items immediately associated with the arrestee, which will necessarily travel with the arrestee to jail.” Brock, [491]*491184 Wash.2d 148 at ¶ 14, 355 P.3d 1118. The court explained:
When the personal item is taken into custody as part of the arrestee’s person, the arrestee’s ability to reach the item during the arrest and search becomes irrelevant.
Rather, the safety and evidence preservation exigencies that justify this “time of arrest” distinction stem from the safety concerns associated with the officer having to secure those articles of clothing, purses, -backpacks, and even luggage, that will travel with the arrestee into custody. Because those items are part of the person,, we recognize the practical reality that the officer seizes those items during the arrest. From that custodial authority flows the officer’s authority to search for weapons, contraband, and destructible evidence.
Id. at ¶¶ 16-17, 355 P.3d 1118 (2015). The court then went on-to conclude that the lapse of time between when Brock had possession of his backpack to when he was arrested and the backpack searched was not the deciding factor as to whether he had the backpack in his actual possession at the time of, or immediately preceding, his arrest. Id. at ¶ 22. The court explained this by stating:
The Court of Appeals’ analysis misapprehends the purpose of the time of arrest -rule. Although -we must draw these exceptions to the warrant requirement narrowly, we do not draw them arbitrarily; the exception must track its underlying justification.... [W]e draw the line of ‘immediately preceding5 with that focus. The proper inquiry is whether possession so immediately precedes arrest that the item is still functionally a part of the arrestee’s person. Put simply, personal items that will go to jail with the arrestee are considered in the arrestee’s “possession” and "are within the scope of the officer’s authority to search.
Id. at ¶ 22. The court went on to hold:
Under these circumstances, the lapse of time had little practical effect on Brock’s relationship to his backpack.... Once the arrest process had begun, the passage of time prior to the arrest did not render it any less a part of Brock’s arrested person.
We hold that when the officer removes the item from the arrestee’s person during a lawful Terry stop and the Terry stop ripens into a lawful arrest, the passage of time does not negate the authority of law justifying the search incident to arrest.
Id. at ¶¶ 23-24. We agree with this reasoning and the conclusion reached by the Supreme Court of Washington. We therefore conclude that where the object searched is immediately associated with the arrestee, such that it is considered 'a part “of the person of the arrestee” that will be taken into custody with him, Robinson applies and no additional justification beyond the lawful arrest is necessary to justify the search.
[¶ 38] This is consistent with the decisions of several other courts. See People v. Marshall, 2012 CO 72, ¶ 16, 289 P.3d 27 (“[Exigencies relied upon by the majority in Gant are not implicated by the search of a person, and articles bn or near that person,' after a lawful arrest.”); United States v. Matthews, 532 Fed.Appx. 211 (3d Cir.2013) (police may search the luggage a person has in his possession at the time of a valid, public arrest, before transporting it to the police station); United States v. Gordon, 895 F.Supp.2d 1011 (D.Haw.2012) (search of the defendant’s duffel bag, which he was carrying over his shoulder at the time of his arrest, was a proper search even though he was handcuffed and in custody at the time of the search). We [492]*492have similarly held “[a]n arrestee’s purse is generally considered an object immediately associated with a person or an extension of the person, similar to a search of the arrestee’s pocket or clothing.” State v. Woinarowicz, 2006 ND 179, ¶ 32, 720 N.W.2d 635. Although Woinaromcz involved a purse and not a backpack, they are very similar — both objects are used to carry personal items and are generally considered an extension of the person.
[¶ 39] The United States.. Supreme Court also, seemed to support this conclusion when it suggested, without directly holding, that inspecting certain physical items “carried by the arrestee” may be reasonable. See Riley v. California, — U.S. -, 134 S.Ct. 2473, 2488-89, 189 L,Ed.2d 430 (2014) (“Modern cell phones, as a category, implicate privacy concerns far beyond those implicated by the search of a cigarette pack, a wallet, or a purse. A conclusion that inspecting the contents of an arrestee’s pockets works no substantial additional intrusion on privacy beyond the arrest itself may make sense as applied to physical items, but any extension of that reasoning to digital data has to rest on its own bottom.”). The Riley Court also noted that Robinson is the. only decision where the Court has had occasion .to apply Chimel to. a search of the contents of an item found on ;an arrestee’s person, but lower courts have approved such searches. Id. at 2488 (“Lower courts applying Robinson and Chimel, however, have approved searches of a variety of personal items carried by an arrestee” (emphasis added)). The court also noted in Riley that it had upheld the search of a zipper bag carried by an arrestee in Draper v. U.S., 358 U.S. 307, 79 S.Ct. 329, 3 L.Ed.2d 327 (1959), but in that case only analyzed the validity of the arrest itself. See Riley v. California, 134 S.Ct. at 2488.
[¶40] Most recently we have the Supreme Court’s statement in Birchfield v. North Dakota, quoted above at ¶ 26.
[¶ 41] Our decisions post-Gcmi involving the scope of a warrantless search incident to an arrest generally have involved the search of an automobile, similar to Belton and Gant, or a home, similar to Chimel In the present case, we are faced with the warrantless search-ineident-to-ar-rest of a backpack, that backpack not being in a vehicle or- in a home but in the defendant’s actual possession immediately preceding his arrest. We conclude that under the facts and circumstances of this case, the search of Mercier’s backpack incident to his arrest was reasonable.
[¶ 42] At the time Mercier’s backpack was searched, he had been placed in the back of a squad car. Mercier had the backpack in his immediate possession prior to being restrained because the officers were allowing him to search through' it to obtain his identification. Once he informed the officers that there was a knife inside the backpack, they handcuffed him for safety purposes and searched him. Shortly thereafter, the officers arrested him, placed him in the back of a squad car, and searched his backpack incident to his arrest. Having no other place to store it, Mercier would have had to bring the backpack along with him into custody. The fact that the backpack sat on the ground for a number, of minutes after Mercier was searching through it and before he was formally arrested had little effect on his relationship to the backpack. It was still an item in Mercier’s possession immediately preceding his arrest and would have to go with him to jail when he was brought into custody. It would be illogical to require police officers to leave the backpack on the public street without checking it, posing a threat to the public and the possibility of its being stolen. [493]*493Similarly, it would be illogical for the officers to take it with them to the correctional center or police station without checking it, posing a threat to themselves, the arres-tee, and the public. The officers would havé been entitled — and expected — to do an inventory search on the backpack upon its arrival at the police station or correctional center. See Illinois v. Lafayette, 462 U.S. 640, 648, 103 S.Ct. 2605, 77 L.Ed.2d 65 (1983) (“[I]t is not ‘unreasonable’ for police, as part of the routine procedure incident to incarcerating an arrested person, to search any container or article in his possession, in accordance with established inventory procedures.”). Such an inventory search would have uncovered the contraband found in Mercier’s backpack.
[¶ 43] Similar to the facts in Brock, “Once the arrest process had begun, the passage of timé prior to the arrest did not render it any less a part of [the defendant’s] arrested' person.” State v. Brock, 184 Wash.2d 148, ¶ 23, 355 P.3d 1118 (2015). As the Matthews court articulated in its holding: ■
[W]hen a valid arrest has been made in a public place, which requires that the ■arrested person be transported from the scene, police may search any luggage that the person has in his possession at the time of the arrest, and which must accompany him to the police station, pri- or to transporting it. Such a search is “reasonable’’ in a twenty-first century where.threats to the safety, of police officers include backpacks that conceal bombs, capable of extreme devastation, which can be triggered remotely. ■
United States v. Matthews, 532 Fed.Appx. 211, 225-26 (3d Cir.2013).
[¶44] Because Mercier had the backpack in his actual .possession immediately preceding his lawful arrest, we conclude a. search thereof was reasonable. The district court properly upheld the search of the backpack incident to Mercier’s arrest. In reaching this conclusion, we acknowledge “the central concern underlying the Fourth Amendment [is] the concern about giving police officers unbridled discretion to rummage at will among a person’s private effects.” Arizona v. Gant, 556 U.S. 332, 345, 129 S.Ct. 1710, 173 L.Ed.2d 485 (2009). We note, therefore, that our holding is narrowly tailored and applies only when an individual has been validly arrested and the property or items searched as part of the arrestee incident to the arrest invariably must be transported along with him or her to the jail or the police station.
V
[¶ 45] Because the district court properly denied the motion'to suppress in this case, we affirm the criminal judgment.
[¶ 46] GERALD W. VANDE WALLE, C.J., concurs..
LISA FAIR McEVERS, J., concurs in the result. .