In Vale v. Louisiana, the U.S. Supreme Court ruled in 1969 that police cannot use an arrest made outside a home as justification to search inside the home without a warrant. The case arose when New Orleans police arrested Albert Vale on drug charges outside his mother's house and then searched inside the house without obtaining a warrant, finding more drugs. The court held that while it is permissible for officers to conduct searches related to arrests, these searches must be limited in scope and not extend into areas where there is no immediate danger or evidence of crime present at the time of arrest. This decision reinforced Fourth Amendment protections against unreasonable searches and seizures by requiring law enforcement officials to obtain warrants before conducting most types of residential searches.

In the dissenting opinion for Vale v. Louisiana, Justice Black argued that the police officers' warrantless entry into and search of Vale's home was unconstitutional under the Fourth Amendment. He disagreed with the majority's view that this case fell within an exception to the requirement for a search warrant because it involved "hot pursuit" of a fleeing suspect. According to Justice Black, there was no immediate or urgent need for law enforcement officials to enter and search Vale's house without obtaining a warrant first as they had already arrested him outside his home on suspicion of selling narcotics. The fact that evidence might be destroyed if not immediately seized did not justify bypassing constitutional protections against unreasonable searches and seizures in his view. Furthermore, he expressed concern about eroding these fundamental rights by creating exceptions based on expediency or convenience rather than necessity.