Florida v. Royer - Impact

Although the Royer case has not been reversed, subsequent decisions by the Court have eroded its importance. In 1991, for example, the Court upheld the warrantless, random stop and search of bus passengers for drugs. In 1996, Justice Rehnquist enjoyed some vindication for his dissent in Royer from the Court's decision in Ohio v. Robinette. In that case, the Court held that a police officer's subjective intentions have no bearing on the legality of a continuing detention, and that a police officer need not advise a detained person that he or she is free to go before the person's consent to a search will be deemed voluntary.