In the United States v. Robinson et al., 1959, the Supreme Court ruled on a case involving search and seizure laws. The defendants were convicted of armed robbery in Washington D.C., but they argued that evidence used against them was obtained through an illegal search by police officers who had no warrant or probable cause to believe that they would find weapons or stolen goods. The court held that when a lawful arrest is made, it is reasonable for the arresting officer to search the person arrested in order to remove any weapons that he might seek to use and also prevent escape with evidence of crime. This decision established what became known as "search incident to lawful arrest" doctrine which allows police officers conducting a lawful arrest to perform a full body search without any additional justification.

In the dissenting opinion for United States v. Robinson et al., Justice Brennan argued that the majority's decision to uphold convictions based on evidence obtained through warrantless searches violated Fourth Amendment protections against unreasonable search and seizure. He contended that a police officer should not have unrestricted authority to conduct a full body search of an arrested individual without first obtaining a warrant, unless there is reasonable belief that the person poses immediate danger or risk of escape. In this case, he believed no such exigent circumstances existed at the time of arrest; thus, any evidence discovered during these searches should be considered inadmissible in court due to its unconstitutional acquisition. Furthermore, he criticized the majority's reliance on common law practices from 18th century England as justification for their ruling because those laws were created under vastly different societal conditions and did not reflect modern American values regarding personal privacy rights.