In the case of Illinois v. Batchelder in 1982, the U.S Supreme Court ruled that a state could not prosecute an individual for conduct that had already been prosecuted by another jurisdiction if both jurisdictions had concurrent power to prosecute. The defendant, Robert Batchelder, was initially charged and convicted in federal court for transporting stolen property across state lines. Later on, he was also charged under Illinois law for theft of the same property. He appealed his conviction arguing it violated his Fifth Amendment right against double jeopardy - being tried twice for the same crime. The Supreme Court agreed with Batchelder's argument and reversed his second conviction stating that although states have broad authority to define crimes and punishments within their borders, they cannot infringe upon rights protected by the Constitution such as protection from double jeopardy.

In the dissenting opinion for Illinois v. Batchelder, Justice Stevens argued that the majority's decision to uphold a warrantless search of an automobile trunk was inconsistent with previous Supreme Court rulings on Fourth Amendment rights. He contended that there were no exigent circumstances justifying such a search and therefore it should not have been allowed without a warrant. Furthermore, he disagreed with the majority's assertion that police officers could reasonably believe they had probable cause to conduct this type of search based on their training and experience alone. Instead, he believed these factors should be considered in conjunction with other evidence when determining whether or not probable cause exists.