In the 2014 case of Jeremy Carroll v. Andrew Carman, et ux, the U.S Supreme Court addressed a Fourth Amendment issue regarding whether police officers must have probable cause to enter and search a home under an implied license (i.e., without explicit permission). The case arose when Kentucky police officers entered Jeremy Carroll's yard without a warrant or his consent while investigating an unrelated matter. They saw marijuana plants through his window and arrested him for cultivation. Carroll argued that this violated his Fourth Amendment rights against unreasonable searches and seizures because they did not have probable cause to enter his property. The court ruled in favor of the Carmans, stating that there is an implicit understanding allowing visitors - including law enforcement - to approach homes by usual access routes (like driveways or walkways) for legitimate purposes such as asking questions or conducting investigations. This "implied license" does not require specific homeowner consent each time nor does it necessitate probable cause on part of law enforcement officials. However, any evidence obtained during these visits must be clearly visible from areas where visitors are allowed; otherwise it may constitute illegal search/seizure activity violating homeowners' constitutional rights.

The dissenting opinion in the case of Jeremy Carroll v. Andrew Carman, et ux argued that the majority's decision to expand qualified immunity for police officers was incorrect and could potentially lead to abuses of power. The dissenters believed that a reasonable person would have known that entering someone’s home without a warrant or exigent circumstances is unconstitutional, thus the officer should not be granted immunity from prosecution. They also expressed concern about setting a precedent where law enforcement can violate constitutional rights without fear of legal consequences as long as they are acting within their professional capacity. This viewpoint emphasized upholding citizens' Fourth Amendment rights against unreasonable searches and seizures over protecting police officers from potential lawsuits.