In the case of Carroll et al. v. United States (1956), the Supreme Court was asked to consider whether evidence obtained through a warrantless search of an automobile could be used in court against the defendants, who were charged with transporting illegal alcohol during Prohibition. The Court ruled that such searches and seizures without a warrant are permissible under certain circumstances, establishing what is now known as the "automobile exception" to the Fourth Amendment's protection against unreasonable searches and seizures. This decision was based on two main factors: first, vehicles can easily be moved out of a locality or jurisdiction while officers obtain a warrant; secondly, it is less reasonable for someone to expect privacy in their vehicle compared to their home or office due to extensive regulation on vehicles by law enforcement agencies.

The dissenting opinion in the Carroll et al. v. United States case argued that the majority's decision to uphold warrantless searches of automobiles based on probable cause was a violation of Fourth Amendment rights against unreasonable searches and seizures. The dissenters believed that this ruling gave law enforcement too much discretion, potentially leading to abuses of power and infringements upon citizens' privacy rights. They contended that any search without a warrant should be considered per se unreasonable unless it falls within one of the few well-delineated exceptions, such as exigent circumstances or consented searches. In their view, an automobile’s mobility did not justify bypassing constitutional protections for its occupants; instead, they suggested other legal means could be used to prevent evidence destruction while obtaining a warrant if necessary.