In the 1984 case of California v. Carney, the U.S. Supreme Court ruled that motor homes are subject to search without a warrant under the automobile exception to the Fourth Amendment's requirement for probable cause and issuance of a search warrant. The court held that because motor homes can be quickly moved, they fall into this category even if they are being used as residences at the time of their search. This decision came about after DEA agents searched Charles R. Carney’s mobile home parked in downtown San Diego without obtaining a warrant first, finding marijuana inside which led to his arrest on drug charges.

In the dissenting opinion for California v. Carney, Justice Stevens argued that the majority's decision to allow warrantless searches of motor homes based on automobile exceptions was flawed. He contended that a motor home is more similar to a house than an automobile due to its function as living quarters and should therefore be afforded the same Fourth Amendment protections against unreasonable searches and seizures. Stevens also criticized the majority's reliance on mobility as justification for their ruling, stating it could potentially lead to further erosion of Fourth Amendment rights if applied broadly. Furthermore, he expressed concern over potential abuse by law enforcement who might use this exception indiscriminately without proper cause or oversight.