In the case of James Michael Flippo v. West Virginia, 1999, the U.S. Supreme Court ruled in favor of Flippo who was convicted for murdering his wife during a camping trip based on evidence found by police officers during an unauthorized search of his belongings at their shared cabin. The court held that the "murder scene exception" to the Fourth Amendment's warrant requirement - which allows law enforcement officials to conduct a full search without obtaining a warrant when they are called to investigate a murder or other serious crime - did not exist and thus could not be used as justification for such searches. This decision reaffirmed that all searches require warrants unless they fall within one of the established exceptions like consent or exigent circumstances, none of which applied here.

In the dissenting opinion for Flippo v. West Virginia, Justice Scalia disagreed with the majority's decision to overturn Flippo's conviction based on an improper search warrant. He argued that there was no clear precedent stating that police officers must obtain a separate warrant before opening a closed container found during a lawful search. In his view, once law enforcement has obtained permission to conduct a search, they should be able to open any containers encountered in order to complete their investigation effectively and efficiently. Furthermore, he contended that even if such rule existed requiring another warrant for closed containers within the scope of original one, it would not apply here because the object in question -a briefcase- is not inherently private or personal like letters or diaries might be considered.