In the United States v. Place case of 1982, the U.S Supreme Court ruled that a 90-minute detention of luggage at an airport for a dog-sniff test constituted an unreasonable seizure under the Fourth Amendment. The defendant, Raymond J. Place, was suspected by law enforcement officers to be carrying narcotics in his luggage while traveling from Miami to New York City via plane. His bags were seized and held for about ninety minutes before being subjected to a sniff-test by a drug-detection dog which indicated presence of drugs in one bag leading to its search and discovery of cocaine inside it. However, on appeal, the court found that although using dogs for detecting drugs does not constitute as 'search' under Fourth Amendment rights; detaining personal property beyond what is considered reasonable time frame without probable cause or warrant violates those rights.

In the dissenting opinion for United States v. Place, Justice Brennan disagreed with the majority's ruling that a 90-minute detention of luggage at an airport was reasonable under the Fourth Amendment. He argued that such a lengthy seizure without probable cause violated constitutional protections against unreasonable searches and seizures. Furthermore, he expressed concern about potential abuses of power by law enforcement officials who might use this decision as justification to detain personal property indefinitely until they could bring in drug-sniffing dogs or other means to conduct warrantless searches. He also criticized the majority's reliance on factors like "reasonable suspicion" which are subjective and can be manipulated by law enforcement officers to justify their actions after-the-fact.