In the 1981 case Washington v. Chrisman, the U.S Supreme Court ruled in favor of law enforcement's right to conduct warrantless searches under certain circumstances. The case involved a police officer who had followed a student into his dorm room without a warrant after arresting him for possession of alcohol as an underage individual. While in the room, he saw drugs and drug paraphernalia in plain view and arrested the student on additional charges. The defendant argued that this constituted an illegal search since there was no warrant or consent given to enter his private residence. However, the court held that once lawful arrest has been made, officers have "the right to remain literally at arm's length from [the] person arrested," which includes following them into their home if they do not explicitly deny entry.

In the dissenting opinion for Washington v. Chrisman, Justice Marshall argued that the majority's decision significantly expanded police powers in a way that threatened Fourth Amendment rights. He contended that allowing an officer to follow a suspect into his private residence without any suspicion of criminal activity was not justified by concerns about officer safety or evidence preservation. The mere fact of lawful arrest does not automatically justify intrusion into all areas where an arrested person might have access. Furthermore, he disagreed with the majority’s view on “immediately associated” concept and believed it should be limited to situations where there is reasonable belief that other persons present may destroy evidence or pose danger to officers if left unattended while they are arresting someone else inside premises. Thus, he concluded this ruling could lead to unjustified invasions of privacy.