In the case of Colorado v. Nunez, 1983, the U.S Supreme Court was asked to consider whether a confession made by an accused person could be used as evidence if it had been obtained without informing them of their Miranda rights. The defendant in this case, Mr. Nunez, had confessed to committing burglary during informal questioning before he was arrested or read his rights. The state court ruled that because he wasn't officially in custody when he confessed and therefore didn't need to be Mirandized first for his statements to be admissible at trial. However, on appeal from Mr.Nunez's lawyers arguing that any statement given without being informed of one’s right should not have been admitted into evidence regardless of custodial status; the Supreme Court declined direct review leaving intact lower court's decision.

In the dissenting opinion for Colorado v. Nunez, it was argued that the majority's decision to allow a warrantless search of an impounded vehicle violated Fourth Amendment protections against unreasonable searches and seizures. The dissent emphasized that there were no exigent circumstances justifying a warrantless search in this case, as the police had already secured control over both the suspect and his vehicle at their station house. It was also pointed out that allowing such searches would create a dangerous precedent where any arrest could justify an automatic car search without regard for individual rights or privacy concerns. Furthermore, they disagreed with the majority's assertion that inventory searches are merely administrative procedures; instead, they viewed them as investigative techniques requiring constitutional scrutiny. They concluded by expressing concern about eroding Fourth Amendment safeguards through expanding exceptions to its requirements.