In the United States v. Watson case of 1975, the Supreme Court ruled that law enforcement officers do not violate the Fourth Amendment when they arrest a suspect without a warrant based on probable cause in public places. The case arose after an officer arrested Robert Allen Watson following information from an informant about his possession of stolen credit cards. Although there was no immediate danger or risk of evidence destruction, and despite having enough time to obtain a warrant, the officer chose to make an unwarranted arrest which led to further incriminating evidence against Watson during post-arrest consent search at police station. In its decision, the court upheld this action as constitutional by citing historical precedent and statutory authority allowing such arrests under federal law.

In the dissenting opinion for United States v. Watson, Justice Potter Stewart argued that the majority's decision to allow warrantless arrests based on probable cause in public places was a misinterpretation of both historical precedent and constitutional law. He contended that such an interpretation could lead to potential abuses of power by law enforcement officers. Furthermore, he disagreed with the majority's reliance on common-law history as justification for their ruling, stating it did not accurately reflect modern societal values or expectations about privacy rights and police powers. Instead, he believed that Fourth Amendment protections should be interpreted more broadly to require warrants for all arrests unless exigent circumstances exist.