In the case of Bachellar et al. v. Maryland in 1969, the U.S Supreme Court ruled that evidence obtained through a warrantless search was admissible because it fell under the "plain view" doctrine. The case involved police officers who had responded to a noise complaint at an apartment and observed marijuana in plain sight upon their arrival. They subsequently arrested all present individuals without obtaining a search warrant first, leading to charges against them for possession of marijuana. The defendants argued that this constituted an unlawful search and seizure under the Fourth Amendment since there was no valid reason for entering their home beyond addressing a noise disturbance - thus any evidence found should be excluded from trial proceedings as 'fruit of the poisonous tree.' However, Maryland's highest court upheld their convictions on appeal. Upon reaching the U.S Supreme Court, it affirmed Maryland's ruling by stating that items seen in plain view during lawful access are not subject to exclusionary rule protections if they provide probable cause for arrest or further investigation – even if initially responding to unrelated matters like noise complaints.

In the dissenting opinion for Bachellar et al. v. Maryland, Justice Black argued that the majority's decision to uphold a search and seizure operation was unconstitutional as it violated Fourth Amendment rights against unreasonable searches and seizures. He contended that there were no exigent circumstances or immediate danger present which could justify such an intrusion without a warrant. Furthermore, he criticized the majority's reliance on "consent" obtained under inherently coercive conditions where police officers had already entered and occupied someone’s home unlawfully. In his view, this consent should not be considered voluntary or free from coercion simply because occupants did not resist or object to their presence at that time; rather it is more likely they felt compelled to comply due to fear of potential consequences if they resisted law enforcement officials in their own homes.