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JUSTICE STEIGMANN delivered the opinion of the court:

In June 2001, the State charged defendant, ElizabethMorales, with possession of drug paraphernalia (720 ILCS600/3.5(a) (West 2000)) and possession of cannabis (not more than2.5 grams of a substance containing cannabis) (720 ILCS 550/4(a)(West 2000)). In December 2001, defendant filed a motion tosuppress the evidence against her, alleging that it was obtainedduring an illegal search. Following a December 2001 hearing, thetrial court granted defendant's motion to suppress evidence.

The State appeals, arguing that the trial court erredby granting defendant's motion to suppress evidence. We reverseand remand.

In lieu of a transcript of trial court proceedings, theparties have submitted to this court a document that is entitled"Bystander's Report of Motion to Suppress Hearing," which issigned by both parties. The report does not bear certificationby the trial court, as is required under Supreme Court Rule323(c) (166 Ill. 2d R. 323(c)). However, even withoutcertification, we may accept the parties' agreed statement offacts as a substitute for a report of proceedings undersubsection (d) of Supreme Court Rule 323. 166 Ill. 2d R. 323(d);see People v. Gerwick, 235 Ill. App. 3d 691, 692-93, 602 N.E.2d93, 94-95 (1992) (in which this court accepted the parties'agreed statement of facts, although it was labeled a bystander'sreport and lacked the trial court's certification). The parties'agreed statement of facts summarizes the testimony and argumentpresented at the December 2001 hearing on defendant's motion tosuppress evidence as follows.

Normal police officer Nathan Poehlman testified thataround 1 a.m. on February 25, 2001, he noticed a parked car in apublic park with the motor running and the lights off. A Normalordinance provides that city parks close at 11 p.m. Poehlmanspoke with the car's two occupants--Michael Garcia, seated in thedriver's seat, and defendant, seated in the front passenger'sseat. Poehlman learned that (1) Garcia's driver's license hadbeen suspended; (2) an active De Witt County warrant wasoutstanding for Garcia's arrest; and (3) the license plate toGarcia's car had been suspended. Based on this information,Poehlman decided to arrest Garcia.

Prior to arresting Garcia, Normal police officer ShaneHackman arrived at the scene. After Garcia was arrested andsecured in a squad car, Poehlman asked defendant to get out ofthe car. While Poehlman spoke with defendant outside the car,Hackman conducted a search of the car that was incident toGarcia's arrest, as well as an inventory search, given that thecar was going to be towed due to expired plates. Defendant wasnot wearing a coat when she was standing outside the car. Defendant did not inform Poehlman that (1) she had any personalproperty in the car, or (2) she needed to retrieve anything frominside the car.

Hackman pulled a jacket from the "console area,"searched it, and asked defendant if it belonged to her. Sheacknowledged that the jacket belonged to her, and Hackman askedPoehlman to look inside the jacket pocket. When he did, Poehlmanfound a black film canister that contained "suspected cannabis"and a blue metal "one-hitter" pipe with burnt cannabis residue. The officers then arrested defendant. Neither Poehlman norHackman obtained defendant's consent to search the jacket. Priorto the search, defendant did not give the officers any reason tosuspect her of criminal activity.

Hackman testified that around 1 a.m., he arrived at thescene to assist Poehlman. Hackman testified similarly toPoehlman regarding the bases for the search of the car--that is,incident to Garcia's arrest and as an inventory search. Duringthe search, Hackman found a jacket in the console area of thecar. He did not try to determine who owned the jacket beforesearching it. He felt the outside of the jacket, looking forweapons. He felt a hard object in the pocket area of the jacket,which he believed to be drug paraphernalia. He then askeddefendant if the jacket belonged to her, and she responded thatit did. He handed the jacket to Poehlman and asked him to lookinside the pocket.

Defendant testified that around 1 a.m. on the day inquestion, she was a passenger in a car being driven by Garcia,whom she was dating. While she and Garcia were sitting in thecar in a public park, the police approached the car and spokewith Garcia. They arrested Garcia for having a suspendedlicense, and Poehlman asked defendant to get out of the car. Shewas not wearing a jacket when she did so. She thought she hadleft her jacket in the backseat. An officer searched the car,discovered her jacket, and asked if it belonged to her. She didnot consent to the search of her jacket, and she did not telleither officer that she had any personal property in the car orthat she needed to retrieve any personal property from the car.

Defense counsel argued that the evidence againstdefendant should be suppressed under People v. James, 163 Ill. 2d302, 645 N.E.2d 195 (1994), because, absent probable cause, theofficers were not justified in searching her jacket without herconsent.

The State argued that the search of defendant's jacketwas justified as (1) a search incident to Garcia's arrest, and(2) an inventory search. The State relied on New York v. Belton,453 U.S. 454, 69 L. Ed. 2d 768, 101 S. Ct. 2860 (1981), andPeople v. Bailey, 159 Ill. 2d 498, 639 N.E.2d 1278 (1994), forits argument that a search incident to a custodial arrest extendsto any containers found within the passenger compartment of thecar.

In January 2002, the trial court entered an ordergranting defendant's motion to suppress evidence. In that order,the court found, in pertinent part, as follows:

"3. Officers made no attempt todetermine the ownership of the coat untilfinding suspected contraband in the pocket,at which time [defendant] identified it asher coat.

4. Defendant did not consent to thesearch of her coat.

5. Since the officers knew [defendant]was a passenger in the vehicle, they had aduty to make an effort to determine ownershipof the coat and obtain [d]efendant's consentto search it.

6. Their failure to do so is not curedby the fact that an inventory search of thevehicle might otherwise have been appropriatedue to the arrest of [Garcia].

7. Any items seized from [defendant's]coat must therefore be suppressed."

This appeal followed.

The State argues that the trial court erred by grantingdefendant's motion to suppress evidence because the search ofdefendant's jacket constituted a lawful search incident toGarcia's arrest. We agree.

Defendant does not address on the merits the State'sargument that the officers lawfully searched defendant's jacketincident to Garcia's arrest. Rather, she contends that the Statehas forfeited this argument by failing to raise it below. Defendant's contention is patently without merit. The agreedstatement of facts, which was signed by defense counsel, clearlyindicates that the State argued at the suppression hearing thatthe search of defendant's jacket was a lawful search incident toarrest under Belton, 453 U.S. 454, 69 L. Ed. 2d 768, 101 S. Ct.2860, and Bailey, 159 Ill. 2d at 503, 639 N.E.2d at 1280.

Moreover, defendant cites no authority for herassertion that to preserve an issue for interlocutory appealunder Supreme Court Rule 604(a)(1) (188 Ill. 2d R. 604(a)(1)),the State must first file a motion to reconsider in the trialcourt. Arguments not supported by citation to authority do notcomply with the requisites of Supreme Court Rule 341(e)(7) and donot merit our consideration on appeal. 188 Ill. 2d R. 341(e)(7);People v. $1,124,905.00 United States Currency, 269 Ill. App. 3d952, 956, 647 N.E.2d 1028, 1031 (1995), rev'd on other grounds177 Ill. 2d 314, 325, 685 N.E.2d 1370, 1375 (1997).

Motion To Suppress Evidence

Generally, a trial court's ruling on a motion tosuppress evidence will not be disturbed unless it is manifestlyerroneous. People v. Ceja, 204 Ill. 2d 332, 347, 789 N.E.2d1228, 1239 (2003). However, de novo review is appropriate when,as here, the facts are not disputed and the sole issue is whethersuppression was warranted. People v. Gipson, 203 Ill. 2d 298,304, 786 N.E.2d 540, 543 (2003).

"The fourth amendment to the United States Constitutiondoes not prohibit all State-initiated searches and seizures; itprohibits only those that are unreasonable." Bailey, 159 Ill. 2dat 503, 639 N.E.2d at 1280. Although warrantless searches areper se unreasonable, a warrantless search may be consideredreasonable if it falls within a specific exception to the fourthamendment's warrant requirement. A search incident to a lawfularrest is a traditional exception to that requirement. Bailey,159 Ill. 2d at 503, 639 N.E.2d at 1280.

In Belton, the United States Supreme Court addressedthe proper scope of a search of the interior of an automobileincident to a lawful custodial arrest of its occupants. Belton,453 U.S. at 459-63, 69 L. Ed. 2d at 774-76, 101 S. Ct. at 2863-65. In that case, after placing all four of the car's occupantsunder arrest, the arresting officer searched the car's interior. He found cocaine in the pocket of the defendant's jacket, whichhe had found on the backseat of the car. Belton, 453 U.S. at456, 69 L. Ed. 2d at 772, 101 S. Ct. at 2862. The Court heldthat "when a policeman has made a lawful custodial arrest of theoccupant of an automobile, he may, as a contemporaneous incidentof that arrest, search the passenger compartment of thatautomobile." Belton, 453 U.S. at 460, 69 L. Ed. 2d at 775, 101S. Ct. at 2864. The Court further held that in suchcircumstances, the police "may also examine the contents of anycontainers found within the passenger compartment." Belton, 453U.S. at 460, 69 L. Ed. 2d at 775, 101 S. Ct. at 2864. The Courtexplained that a "container" includes "any object capable ofholding another object. It thus includes closed or open glovecompartments, consoles, or other receptacles located anywherewithin the passenger compartment, as well as luggage, boxes,bags, clothing, and the like." Belton, 453 U.S. at 460-61 n.4,69 L. Ed. 2d at 775 n.4, 101 S. Ct. at 2864 n.4.

In so holding, the Court reiterated that

"a lawful custodial arrest creates asituation which justifies the contemporaneoussearch without a warrant of the personarrested and of the immediately surroundingarea. Such searches have long beenconsidered valid because of the need 'toremove any weapons that [the arrestee] mightseek to use in order to resist arrest oreffect his escape' and the need to preventthe concealment or destruction of evidence." Belton, 453 U.S. at 457, 69 L. Ed. 2d at 773,101 S. Ct. at 2862, quoting Chimel v.California, 395 U.S. 752, 763, 23 L. Ed. 2d685, 694, 89 S. Ct. 2034, 2040 (1969).

Belton thus essentially held that the entire passengercompartment lies within the reach of the arrested occupant. Byso holding, Belton sought to provide a workable "bright-line"rule for police and thereby "avoid case-by-case evaluations ofwhether the arrestee's area of control within the automobileextended to the precise place where the officer found the weaponor evidence." People v. Stehman, 203 Ill. 2d 26, 34, 783 N.E.2d1, 5 (2002). The Belton Court also noted that "'[a] custodialarrest of a suspect based on probable cause is a reasonableintrusion under the [f]ourth [a]mendment; that intrusion beinglawful, a search incident to the arrest requires no additionaljustification.'" Belton, 453 U.S. at 461, 69 L. Ed. 2d at 775-76, 101 S. Ct. at 2864, quoting United States v. Robinson, 414U.S. 218, 235, 38 L. Ed. 2d 427, 440-41, 94 S. Ct. 467, 477(1973).

The Supreme Court of Illinois's decision in Baileyillustrates the application of Belton's bright-line rule. InBailey, a police officer had stopped a car driven by thedefendant, Brian Bailey, for not having a front license plate. In addition to Bailey, four occupants were in the car. After theofficer determined that Bailey's driver's license had beensuspended, he arrested Bailey, handcuffed him, searched him, andplaced him in the back of the squad car. The officer thendirected the passengers out of the car and searched the car'sinterior. He discovered a container in the glove compartmentthat contained drug paraphernalia. That evidence became thebasis for an additional charge against Bailey. Bailey, 159 Ill.2d at 501, 639 N.E.2d at 1279.

Our supreme court held that Belton justifies the searchof a vehicle incident to arrest without regard to the nature ofthe offense supporting the arrest. Bailey, 159 Ill. 2d at 505,639 N.E.2d at 1281. In so holding, the court noted that"[a]lthough a search incident to arrest is based on the need todisarm and discover evidence, the authority to search does notdepend on the probability in a particular case that weapons wouldin fact be found or evidence would in fact be destroyed." Bailey, 159 Ill. 2d at 504, 639 N.E.2d at 1281; see also Peoplev. Allibalogun, 312 Ill. App. 3d 515, 519, 727 N.E.2d 633, 637(2000) ("A search of a vehicle under Belton is permissible evenafter the defendant has been removed from the car, handcuffed,and placed in a squad car, and even if he is in the custody ofseveral officers").

In Wyoming v. Houghton, 526 U.S. 295, 143 L. Ed. 2d408, 119 S. Ct. 1297 (1999), the Supreme Court consideredwhether, when a police officer searches a car based on probablecause to believe that the car contains contraband, he may searcha passenger's personal belongings found inside the vehicle. Inthat case, a highway patrol officer stopped a car for speedingand driving with a faulty brake light. In addition to the maledriver, two females were seated in the front passenger seat. While questioning the driver, the officer noticed that the driverhad a hypodermic syringe in his shirt pocket. Houghton, 526 U.S.at 297-98, 143 L. Ed. 2d at 413, 119 S. Ct. at 1299. Afterreturning to his patrol car to obtain a pair of gloves, heinstructed the driver to get out of the car and place the syringeon the hood. The officer asked the driver why he had thesyringe, and the driver said that he used it to take drugs. Atthat point, a backup officer ordered the two passengers out ofthe car. Meanwhile, the primary officer searched the passengercompartment for contraband. On the backseat, he found a purse,which one of the passengers claimed as hers. The purse containeddrug paraphernalia and a syringe containing methamphetamine. Thepassenger was later charged with possession of methamphetamine. Houghton, 526 U.S. at 297-98, 143 L. Ed. 2d at 413, 119 S. Ct. at1299. Prior to her trial, the passenger challenged the search ofher purse on fourth amendment grounds.

The Wyoming Supreme Court held that the search of thepassenger's purse violated the fourth amendment because theofficer knew or should have known that the purse did not belongto the driver, but to one of the passengers. Houghton, 526 U.S.at 299, 143 L. Ed. 2d at 414, 119 S. Ct. at 1300. However, theUnited States Supreme Court disagreed, holding that policeofficers with probable cause to search a car may inspectpassengers' belongings found in the car that are capable ofconcealing the object of the search. Houghton, 526 U.S. at 307,143 L. Ed. 2d at 419, 119 S. Ct. at 1304. In so holding, theCourt cited its previous holding in United States v. Ross, 456U.S. 798, 72 L. Ed. 2d 572, 102 S. Ct. 2157 (1982), that probablecause to search a lawfully stopped car justifies the search ofevery part of the car and its contents that may conceal theobject of the search. The Court noted that (1) no limitation wasexpressed in Ross restricting searches to only those containersowned by the driver, and (2) Ross had been broadly applied tojustify searches of all containers within a car, withoutqualification as to ownership. Houghton, 526 U.S. at 301, 143 L.Ed. 2d at 415, 119 S. Ct. at 1301.

The Court further reasoned that passengers, no lessthan drivers, have a reduced expectation of privacy with regardto the property that they transport in cars. Houghton, 526 U.S.at 303-04, 143 L. Ed. 2d at 417, 119 S. Ct. at 1302. Meanwhile,the governmental interests at stake are substantial: "Effectivelaw enforcement would be appreciably impaired without the abilityto search a passenger's personal belongings when there is reasonto believe contraband or evidence of criminal wrongdoing ishidden in the car." Houghton, 526 U.S. at 304, 143 L. Ed. 2d at417, 119 S. Ct. at 1302. The Court recognized that a criminalcould hide contraband in a passenger's belongings as readily asin other containers in the car, and rejected as impractical anyrequirement that before conducting vehicle searches officers mustdetermine (1) ownership of containers, or (2) whether the driverand passenger had the opportunity to conspire to concealcontraband.

"To require that the investigating officerhave positive reason to believe that thepassenger and driver were engaged in a commonenterprise, or positive reason to believethat the driver had time and occasion toconceal the item in the passenger'sbelongings, surreptitiously or with friendlypermission, is to impose requirements soseldom met that a 'passenger's property' rulewould dramatically reduce the ability to findand seize contraband and evidence of crime. *** [O]nce a 'passenger's property'exception to car searches became widelyknown, one would expect passenger-confederates to claim everything as theirown. And one would anticipate a bog oflitigation--in the form of both civillawsuits and motions to suppress in criminaltrials--involving such questions as whetherthe officer should have believed apassenger's claim of ownership, whether heshould have inferred ownership from variousobjective factors, whether he had probablecause to believe that the passenger was aconfederate, or to believe that the drivermight have introduced the contraband into thepackage with or without the passenger'sknowledge." Houghton, 526 U.S. at 305-06,143 L. Ed. 2d at 418, 119 S. Ct. at 1303.

Although Houghton involved a vehicle search based onprobable cause, courts have applied its reasoning, in conjunctionwith Belton, when faced with the issue now before us--namely,whether, upon the lawful arrest of the operator of a vehicle, awarrantless search incident to that arrest may properly extend toa container situated in the passenger compartment of the vehiclewhen that container belongs to a passenger who has not beenarrested at the time of the search. See, e.g., State v.Tognotti, 663 N.W.2d 642, 648 (N.D. 2003) (holding that incidentto the valid arrest of a car's occupant, the arresting officercould search the contents of a nonarrested occupant's purse thatwas voluntarily left inside the car and citing relevant cases). We agree with this analysis.

Houghton well articulates the need for maintainingclear and workable rules for police searches, and we concludethat imposing a restriction on vehicle searches incident toarrest based on ownership of containers or other articles leftinside the vehicle would "unnecessarily dim" Belton's bright-linerule. See Tognotti, 663 N.W.2d at 646. When police stop a carwith multiple passengers and arrest one of them, the need for thepolice to discover either hidden weapons that could be turnedupon them or evidence that could be destroyed is no less acutethan when the police stop a vehicle and arrest its sole occupant. Indeed, because of the number of people involved, the need may beeven greater. Given that third-party ownership of an item withina car's passenger compartment would not necessarily prevent anarrestee from gaining access to it, third-party ownership of anitem should not bar police from searching that item in the samemanner as if it were owned by the arrestee. To hold otherwisewould create a rule that is not only impracticable but alsopotentially dangerous to police officers. We thus concludethat in this case, Hackman and Poehlman were justified insearching defendant's jacket when they searched Garcia's carincident to his arrest. Accordingly, we hold that the trialcourt erred by suppressing the evidence found therein. See Statev. Ray, 260 Neb. 868, 876-77, 620 N.W.2d 83, 89 (2000) (NebraskaSupreme Court holding that upon the lawful arrest of the driver,a warrantless search incident to that arrest properly extended toa knapsack in the passenger compartment that belonged to apassenger who had not been arrested at the time of the search);State v. Steele, 613 N.W.2d 825, 830 (S.D. 2000) (Supreme Courtof South Dakota holding that a search incident to the driver'sarrest extended to a passenger's purse, even though the policeofficer had requested that the passenger leave the purse in thecar); State v. Pallone, 236 Wis. 2d 162, 188, 613 N.W.2d 568, 581(2000) (Supreme Court of Wisconsin holding that the warrantlesssearch of a passenger's duffel bag was a valid search incident tothe arrest of the driver); People v. McMillon, 892 P.2d 879, 884-85 (Colo. 1995) (Supreme Court of Colorado held that the searchof a passenger's purse was valid as part of a search incident tothe driver's arrest); State v. Moore, 619 So. 2d 376, 377 (Fla.Dist. Ct. App. 1993) (Florida appellate court held that policehad the right to search a passenger's purse incident to thearrest of the driver, and police did not need the passenger'sconsent).

In so holding, we note that defendant's reliance onJames, 163 Ill. 2d 302, 645 N.E.2d 195, is misplaced. In James,the defendant, Delores James, was a passenger in a car that wasstopped by the police. The officers directed the driver, James,and a third passenger to step out of the car. When James got outof the car, she left her purse on the front-passenger seat. Anofficer escorted James away from the car. Without James'sknowledge, the driver of the car consented to a search of thecar. During that search, officers opened James's purse and foundcocaine. James was arrested and charged with unlawful possessionof a controlled substance (720 ILCS 570/402(c) (West 1992)). James, 163 Ill. 2d at 304, 645 N.E.2d at 197.

The trial court granted James's motion to suppress theevidence, and on appeal, this court reversed. People v. James,242 Ill. App. 3d 675, 612 N.E.2d 96 (1993). James appealed tothe Supreme Court of Illinois, and that court reversed our rulingand affirmed the trial court's judgment. In so doing, thesupreme court first determined that the sole justification forthe officers' search of the car was the driver's consent. James,163 Ill. 2d at 313, 645 N.E.2d at 201. Thus, the court definedthe issue before it as whether the officer was justified insearching the defendant's purse under the apparent authorityrule. The court concluded that the officer acted unreasonablywhen he searched the purse while ignorant of the identity of itsowner (James, 163 Ill. 2d at 319, 645 N.E.2d at 204) and that theapparent authority rule did not allow law enforcement officers to"'proceed without inquiry in ambiguous circumstances'" (James,163 Ill. 2d at 319, 645 N.E.2d at 203, quoting 3 W. LaFave,Search & Seizure