In the case of Florida v. Jimeno, the U.S. Supreme Court ruled in favor of law enforcement's right to search a vehicle and any containers within it after obtaining consent from the driver or owner. The defendant, Luz Piedad Jimeno, had been pulled over for a traffic violation when police officers asked if they could search his car for drugs; he agreed without limitation. During their search, officers found cocaine inside a folded paper bag on the floorboard and arrested him on drug charges. Jimeno argued that while he gave permission to search his car, this did not extend to closed containers within it such as the paper bag where drugs were discovered. However, in its decision delivered by Justice Antonin Scalia in 1991 (although heard in 1990), the court held that general consent given by an individual allows police officers to inspect all areas and items where evidence might be found unless explicitly limited at time of consent.

In the dissenting opinion for Florida v. Jimeno, Justice Marshall argued that the majority's decision was too broad and did not adequately protect citizens' Fourth Amendment rights against unreasonable searches and seizures. He contended that an individual's general consent to a search of their vehicle should not automatically extend to closed containers within the vehicle unless it is explicitly stated or there are clear indications suggesting such permission. In this case, he believed that Mr. Jimeno had only given consent for a general search of his car but had not specifically agreed to have a folded paper bag inside searched as well, which ultimately led to the discovery of cocaine evidence used against him in court. Therefore, according to Justice Marshall’s view, this constituted an unreasonable search under the Fourth Amendment.