Warrantless searches of containers had historically been sustained under the exceptions to the fourth amendment protections developed for cases where exigent circumstances require immediate action. The Supreme Court of the United States then limited warantless container searches in United States v. Chadwick and Arkansas v. Sanders but these limitations were subject to various interpretations by the lower courts. This Note examines the various interpretations of these conflicts and their areas of conflict. It then argues for a strict interpretation of the Supreme Court limitations which is more consistent with the traditional exceptions to the fourth amendment's protections against unreasonable searches and seizures.
Warrantless Container Searches Under the Automobile and Search Incident Exceptions,
9 Fordham Urb. L.J. 185
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