In the 1978 case Arkansas v. Sanders, the U.S. Supreme Court ruled that police officers violated the Fourth Amendment when they opened a suitcase without a warrant after stopping a taxi in which Robert Sanders was riding. The police had received information from an informant that Sanders would be carrying marijuana in his suitcase and stopped him based on this tip-off. They seized his suitcase but did not open it until later at the station, where they found marijuana inside. The court held that although seizing of luggage upon probable cause is permissible under certain circumstances, opening it without obtaining a search warrant constitutes an unreasonable search and seizure as per Fourth Amendment protections unless exigent circumstances exist - such as risk of immediate destruction of evidence or danger to officers' safety - none of which were present in this case.

In the dissenting opinion for Arkansas v. Sanders, Justice Blackmun argued that the majority's decision to require a warrant before searching luggage seized from an automobile was inconsistent with previous rulings and unnecessarily complicated law enforcement procedures. He contended that once probable cause had been established, as it was in this case when officers observed what they believed to be marijuana in Sanders' suitcase, there should not be additional restrictions on searches beyond those already outlined by the Fourth Amendment. The distinction made by the majority between containers carried within vehicles and other types of personal property seemed arbitrary to him; he saw no reason why different rules should apply based solely on where an item is located at the time of seizure. Furthermore, he expressed concern about practical implications of requiring warrants for such searches - specifically how it could delay investigations and potentially allow evidence or contraband to be destroyed or removed while police are obtaining a warrant.