In the case of Illinois v. Lafayette, 1982, the United States Supreme Court ruled that police officers are allowed to search any container found within an arrestee's possession at the time of arrest without a warrant. The case arose when a man was arrested for disturbing peace and his shoulder bag was searched at the station where police discovered drugs. He argued that this violated his Fourth Amendment rights against unreasonable searches and seizures as there was no warrant or probable cause to search his bag. However, in a unanimous decision, Justice William Rehnquist wrote for the court stating that such searches were not only necessary for officer safety but also to prevent evidence from being destroyed or concealed by suspects after their arrest.

In the dissenting opinion for Illinois v. Lafayette, Justice Brennan, joined by Justices Marshall and Blackmun, argued that the majority's ruling was inconsistent with previous Fourth Amendment jurisprudence. They contended that a warrantless search of an arrestee’s personal property should only be allowed if it is either to disarm the suspect or to preserve evidence - neither of which were applicable in this case where police searched a shoulder bag after arresting Lafayette on minor charges unrelated to its contents. The dissenting justices believed that allowing such searches without any probable cause violated constitutional protections against unreasonable searches and seizures. Furthermore, they criticized the majority for creating an exception based on convenience rather than necessity or immediate danger.