In Harris v. United States (1967), the U.S. Supreme Court ruled that a search incident to an arrest could include the entire area within the immediate control of the suspect, including areas from which he might gain possession of a weapon or destructible evidence. The case involved Richard Harris who was arrested for attempting to use stolen credit cards at a department store in Washington D.C., and during his arrest, police officers discovered additional stolen credit cards hidden inside his car parked nearby without obtaining a warrant first. Harris argued this violated his Fourth Amendment rights against unreasonable searches and seizures but the court disagreed stating that it was reasonable for officers to search any area into which an arrested person might reach in order to grab a weapon or evidentiary items.

In the dissenting opinion for Harris v. United States, Justice William O. Douglas argued that the majority's decision to allow evidence obtained through a warrantless search of an impounded vehicle violated the Fourth Amendment rights of American citizens. He contended that there was no emergency or exigent circumstance justifying such a search without obtaining a proper warrant first. Furthermore, he pointed out that police had ample time and opportunity to secure one before conducting their investigation but chose not to do so. In his view, this case represented another instance where law enforcement overstepped its bounds in violation of constitutional protections against unreasonable searches and seizures - something which should be checked by courts rather than condoned.