In the 1999 case New York v. Michael Hill, the U.S Supreme Court addressed a matter of criminal procedure and Fourth Amendment rights. The defendant, Michael Hill, was convicted for possession of a weapon after police officers conducted an unwarranted search on his bag without his consent during a traffic stop in New York City. He appealed this conviction arguing that it violated his Fourth Amendment right against unreasonable searches and seizures as there was no probable cause or reasonable suspicion to justify the search. However, the court ruled against him stating that under certain circumstances such as ensuring officer safety during traffic stops; police may conduct protective searches even if they lack probable cause or reasonable suspicion to believe that crime is being committed by those stopped.

In the dissenting opinion for New York v. Michael Hill, it was argued that the majority's decision to uphold a warrantless search based on an anonymous tip violated Fourth Amendment protections against unreasonable searches and seizures. The dissenting justices believed that allowing such searches without requiring police officers to establish probable cause or verify the reliability of anonymous tips could lead to potential abuses of power. They contended that this ruling would undermine citizens' constitutional rights and privacy by giving law enforcement too much discretion in deciding when a warrantless search is justified. Furthermore, they expressed concern about relying heavily on an officer's subjective judgment rather than objective evidence in determining whether there are reasonable grounds for suspicion.