In the case of Adams, Warden v. Williams (1971), the U.S Supreme Court ruled in favor of law enforcement officers' right to conduct a limited protective search for weapons based on reasonable suspicion. The case arose when a police officer in Connecticut received an anonymous tip about an individual carrying narcotics and having a gun at his waist. Acting on this information, the officer approached the suspect's car and asked him to step out; instead, he reached towards where it was reported that he had his gun. In response, the officer reached through the open window and found a loaded revolver in plain view which led to further discovery of drugs upon arrest. The defendant argued that this violated his Fourth Amendment rights against unreasonable searches and seizures as there was no probable cause for such action by law enforcement officers. However, with 6-3 decision court held that while full-blown searches require probable cause under Fourth Amendment protections against unreasonable searches or seizures; frisks or pat-downs can be justified if there is reasonable belief that person may be armed or dangerous even without any specific evidence of criminal activity.

In the dissenting opinion for Adams, Warden v. Williams, Justice William O. Douglas argued that the majority's decision was a significant departure from established Fourth Amendment principles which protect individuals against unreasonable searches and seizures. He contended that allowing police officers to conduct warrantless searches based on information provided by an informant without any verification of its reliability undermines these constitutional protections. According to him, this ruling could potentially lead to abuses of power as it gives law enforcement excessive discretion in deciding when and where they can search or seize property or persons without a warrant. Furthermore, he expressed concern over the erosion of individual privacy rights due to such practices being sanctioned by the court.