Arkansas v. Sanders
In rendering a decision in Sanders, the Court concerned itself with aspects of the case comparable to United States v. Chadwick where evidence was illegally obtained under similar circumstances. As in Chadwick, police acting on probable cause opened luggage found in the trunk of a parked car and searched it without a warrant. The majority justices reasoned that in both cases there was no danger of law enforcement losing the luggage or its contents since the containers were under the exclusive control of the arresting officers. Thus, the Court concluded the state failed to demonstrate a need for warrantless search of property stored in the trunk of a stopped automobile; like the vehicle in which it rode, the luggage was no longer mobile. Arresting officers had to assess the likelihood of an automobile leaving the scene at the point immediately before a search commenced. In circumstances where police had already seized the object of their interest and held it directly under their control, a search could not be conducted without a warrant. Thus, in rendering the Court's decision, the justices provided specific guidance for law enforcement and the lower courts. The Warrant Clause contained in the Fourth Amendment applies to personal luggage taken from an automobile to the same degree it applies to luggage seized in other locations.