In the 1981 case Michigan v. Thomas, the U.S Supreme Court ruled in favor of Michigan, reversing a decision by the Michigan Court of Appeals that had suppressed evidence obtained during a warrantless search. The police officers involved had entered an apartment to arrest two individuals on felony charges and while inside, they noticed drug paraphernalia in plain view which led them to conduct further searches resulting in more incriminating evidence being found. The defendant argued this was a violation of his Fourth Amendment rights against unreasonable searches and seizures as there was no exigent circumstance or consent given for entry into his home without a warrant. However, the Supreme Court held that because officers were lawfully present within Thomas's residence under valid arrest warrants for other occupants at the time they discovered contraband items in plain sight; therefore it did not violate any constitutional protections.

The dissenting opinion in the case of Michigan v. Thomas argued that the majority's decision to uphold a warrantless search and seizure was inconsistent with previous Supreme Court rulings on Fourth Amendment rights. The dissenters believed that there were no exigent circumstances justifying a warrantless entry into the defendant's home, as required by precedent for such an intrusion to be considered reasonable under the Fourth Amendment. They contended that police had ample opportunity to secure a warrant before entering Thomas' residence, given they had been surveilling him for several hours prior without any immediate threat or danger posed. Therefore, according to this view, upholding such an action could potentially erode constitutional protections against unreasonable searches and seizures.