In Robbins v. California[case]Robbins v. California[Robbins v. California] (1981), the Supreme Court ruled that police officers could conduct a warrantless search of a package in an automobile only if the contents of the package were in plain view. However, in Ross, police conducting a search of a car trunk had opened a closed paper bag to discover that it contained heroin. Later, they also found a zippered pouch that contained cash in the trunk. A lower court denied the defendant’s motion to suppress the evidence, and he was convicted of possessing heroin with intent to sell.Fourth Amendment;Ross, United States v.[Ross, United States v.]Automobile searches;Ross, United States v.[Ross, United States v.]

By a 6-3 vote, the Supreme Court largely abandoned Robbins and ruled that packages in automobiles could be searched without a warrant if the police had probable cause the same standard a magistrate should use in issuing a warrant. Justice Thurgood Marshall dissented, arguing that a police officer was not trained as a magistrate and should not be given the same power as a magistrate to determine probable cause. Justice William J. Brennan, Jr., joined in the dissent, and Justice Byron R. White agreed with it.

Automobile searches

Due process, procedural

Exclusionary rule

Fourth Amendment

Mapp v. Ohio

Maryland v. Buie

Michigan Department of State Police v. Sitz

Search warrant requirement