In the 1973 case United States v. Robinson, the US Supreme Court ruled that police officers have the right to conduct a full body search of an individual who has been lawfully arrested, regardless of whether they suspect that person is carrying a weapon or contraband. The case arose when Officer Richard Jenks arrested Willie Robinson for driving with a revoked license and subsequently discovered heroin in his coat pocket during a pat-down search. Robinson was convicted on drug charges but appealed on grounds that the drugs were found through an unlawful search since there was no reason to believe he had weapons or contraband at time of arrest. However, in its decision, the court held that such searches are not violations of Fourth Amendment protections against unreasonable searches and seizures because they serve legitimate interests related to officer safety and evidence preservation.

In the dissenting opinion for United States v. Robinson, Justice Marshall argued that the majority's decision to allow a full search of an individual arrested for any crime was overly broad and violated Fourth Amendment protections against unreasonable searches. He contended that there should be limitations on such searches based on the nature of the offense, as not all offenses would reasonably warrant a thorough body search. For instance, in this case where Robinson was initially stopped for driving without a license - a minor traffic violation - it seemed excessive to permit such an invasive procedure without specific cause or suspicion of further criminal activity. Furthermore, he criticized the majority's reliance on historical practices rather than constitutional principles in their ruling.