In the 1928 case of Manley v. State of Georgia, the U.S Supreme Court addressed an appeal from a man convicted for violating Georgia's Prohibition Act by possessing and transporting alcohol. The defendant argued that his Fourth Amendment rights were violated when police officers searched his car without a warrant and found liquor in it. However, the court ruled against him stating that automobiles are not protected under the Fourth Amendment to the same extent as homes or offices due to their mobility factor which often makes obtaining warrants impractical. Therefore, if law enforcement has probable cause to believe there is contraband inside an automobile on public roads, they may search it without securing a warrant first. This ruling set precedent for what is now known as "automobile exception" in American jurisprudence.

In the dissenting opinion for Manley v. State of Georgia, Justice Oliver Wendell Holmes Jr. argued that the majority's decision to uphold a state law banning interracial marriage was based on an outdated and prejudiced understanding of racial differences. He contended that such laws were not only discriminatory but also violated individuals' constitutional rights to marry whomever they choose regardless of race or ethnicity. Furthermore, he criticized the court's reliance on historical precedent in making its ruling, asserting that societal norms and values change over time and thus legal interpretations should evolve accordingly. In his view, upholding this law represented a failure by the court to adapt to changing social attitudes towards race relations and interracial marriage.