There is a well-recognized lack of consistency and clarity in fourth amendment decisions. At times, each search and seizure case seen is unique and the decisions appear to rest on factual determinations rather than on legal principles. Nonetheless, it is desirable to have some understanding of the basic principles of the fourth amendment, and the way in which these principles affect individual cases.
Ronald J. Bacigal, Warrantless Searches and Seizures in Virginia, 17 U. Rich. L. Rev. 721 (1983).