In the 1982 case of Illinois v. Andreas, the United States Supreme Court ruled that a warrantless search and seizure did not violate the Fourth Amendment rights of an individual if they had no reasonable expectation of privacy in regard to the item seized. The defendant, Andreas, was arrested after customs officials intercepted a package containing cocaine addressed to him from Panama. After replacing most of the cocaine with flour and delivering it under surveillance, law enforcement officers arrested Andreas when he accepted delivery at his apartment. He was released on bail but rearrested two months later when another similar package arrived for him from Panama which also contained cocaine replaced by flour as before. The court held that since both packages were essentially identical and their contents known due to prior lawful examination by customs agents, opening up second one without a warrant didn't infringe upon any legitimate expectation of privacy because its contents were already known or anticipated.

In the dissenting opinion for Illinois v. Andreas, Justice Brennan disagreed with the majority's decision to uphold the warrantless search of a container that had previously been lawfully opened and inspected by customs officials. He argued that once Andreas regained possession of his suitcase after it was initially searched at customs, he held an expectation of privacy in its contents again. Therefore, any subsequent searches without a warrant violated his Fourth Amendment rights against unreasonable searches and seizures. The fact that authorities knew what was inside due to prior lawful inspection did not justify bypassing constitutional protections on later occasions according to him. Furthermore, he expressed concern about potential abuse from this ruling as police could potentially use knowledge gained from one legal search to conduct multiple future illegal ones without warrants or probable cause.