Most people consider automobiles to be a safe place to store personal effects. But just as innocent articles can be kept in automobiles, so can contraband or other evidence of crime. Thus, courts have had to apply the law of search and seizure-which once spoke primarily to the security of the home-to a new setting. The courts treatment has not always been consistent. With a proper warrant, the search of an automobile is valid; but the more perplexing question is, "When is such a search valid without a warrant?" This comment attempts to answer that question, in part, by surveying and cataloging the law in Virginia on warrantless searches and seizures of automobiles.

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