In Lo-Ji Sales, Inc. v. New York (1978), the U.S Supreme Court ruled that a search warrant issued to law enforcement officers in Tompkins County, NY was unconstitutional because it lacked particularity and allowed for an overbroad general search of an adult bookstore. The warrant authorized the seizure of any obscene materials found within the store but did not specify which items were to be seized or what constituted obscenity. This gave officers unrestricted discretion during their search and seizure operation, violating Fourth Amendment protections against unreasonable searches and seizures. The court held that warrants must describe with specificity the items to be seized rather than leaving this determination up to individual officers' judgment at the time of execution.

In the case of LO-JI SALES, INC. v. NEW YORK, Justice Rehnquist dissented from the majority opinion and argued that there was no violation of Fourth Amendment rights in this case because a search warrant had been issued by a neutral magistrate who found probable cause to believe that obscene materials were being sold at Lo-Ji Sales' store. He contended that it was not necessary for the warrant to specify each item to be seized since obscenity is not protected by First Amendment rights and therefore does not require such specificity under existing law. Furthermore, he believed that allowing police officers discretion in determining which items are obscene during their search did not constitute an unconstitutional general warrant as long as they acted within reasonable limits set forth by the issuing judge.