In the case of Cardwell, Warden v. Lewis in 1973, the U.S. Supreme Court ruled on whether a warrantless search and seizure of an automobile's exterior violated Fourth Amendment rights against unreasonable searches and seizures. The defendant was convicted for murder based on evidence obtained from tire tracks left at the crime scene which matched those found on his car parked in a public place. His appeal argued that this constituted an illegal search as no warrant had been issued to inspect his vehicle’s tires or take paint scrapings from its exterior. The court held that such inspection did not violate any constitutional rights because it involved only external parts of the vehicle visible to anyone who might walk by, thus there was no reasonable expectation of privacy being breached under these circumstances. Moreover, since automobiles are mobile by nature and can be quickly moved out-of-state or destroyed before a warrant is secured; they fall under what is known as 'automobile exception' allowing police officers to conduct certain types of searches without obtaining a warrant.

In the dissenting opinion for Cardwell v. Lewis, Justice William O. Douglas argued that the majority's decision violated the Fourth Amendment rights of citizens against unreasonable searches and seizures. He contended that a warrant should have been obtained before taking paint scrapings from an impounded vehicle as evidence in a murder investigation because it constituted a search under constitutional law. The fact that the car was already impounded did not negate this requirement, according to Douglas; he believed there were no exigent circumstances justifying such action without obtaining prior judicial approval through a warrant based on probable cause.