Two recent decisions by the United States Supreme Court have added a new dimension to the law of search and seizure of automobiles and containers found within motor vehicles. The plurality opinion in Robbins v. California'held that a closed opaque container found in the luggage compartment of a station wagon during the course of a lawful vehicle search could not be seized without a warrant. However, in New York v. Belton, a majority held that a police officer, incident to a lawful custodial arrest of an occupant of an automobile, may search the passenger compartment of that automobile and examine contents of any containers, open or closed, found therein.
James M. McCauley,
Search and Seizure of Containers Found in Automobiles: The Supreme Court Struggles for a "Bright Line" Rule,
U. Rich. L. Rev.
Available at: http://scholarship.richmond.edu/lawreview/vol16/iss3/7