In the 1992 case of Edward Soldal, et ux. v. Cook County, Illinois et al., the U.S Supreme Court ruled that a property owner's Fourth Amendment rights were violated when local law enforcement officers assisted in an unlawful eviction without due process. The Soldals' mobile home was towed away despite their protests and police did nothing to prevent it because they considered it a civil matter. The court held that this constituted an unreasonable seizure under the Fourth Amendment as it involved interference with the Soldals' possessory interest in their home and was carried out by state actors (the police). This decision clarified that even if no search for evidence is conducted, any substantial government intrusion into privacy interests constitutes a 'seizure', thus expanding protections under the Fourth Amendment.

In the dissenting opinion for Edward Soldal, et ux. v. Cook County, Illinois et al., Justice Clarence Thomas argued that while the actions of the police officers were wrong and possibly actionable under state law or other provisions of federal law, they did not constitute a violation of the Fourth Amendment's protection against unreasonable seizures. He contended that this amendment was intended to protect individuals' privacy rights rather than their property interests per se. In his view, since there was no invasion of privacy in this case (the eviction being carried out in broad daylight with Soldal's knowledge), there could be no Fourth Amendment violation. This interpretation is based on a historical understanding of what "unreasonable searches and seizures" meant at the time when it was written into Constitution - an intrusion into someone’s private affairs without proper authority or justification.