In the case of Terry Brice Horton v. California, the U.S. Supreme Court examined whether evidence seized during a search that was not specifically authorized by a warrant could be used in court. The police had obtained a warrant to search for stolen jewelry but ended up finding illegal weapons instead, which they seized and used as evidence against Horton. He argued this violated his Fourth Amendment rights against unreasonable searches and seizures since the items were not listed on the warrant. The Supreme Court ruled 5-4 in favor of California, stating that while it is preferable for officers to list all items they expect to find in their application for a search warrant, failure to do so does not automatically make seizure of those unlisted items unconstitutional if they are found while executing lawful authority (in "plain view"). This decision expanded upon previous rulings regarding plain-view doctrine - an exception allowing officers to seize evidence without a specific warrant if it's clearly involved in criminal activity.

In the dissenting opinion for Horton v. California, Justice Brennan argued that the majority's decision blurred the line between searches incident to arrest and those justified by probable cause. He believed that this could potentially lead to abuse of power by law enforcement officers who might manipulate circumstances to justify warrantless searches. Justice Brennan emphasized that a search should only be permitted if it is strictly within the boundaries set out in a validly obtained warrant or falls under one of few carefully delineated exceptions to the warrant requirement. In his view, allowing an officer's subjective intent or belief about what he would find during a search was not enough justification for such action without obtaining proper legal authorization first.