University of Miami Law Review


In two recent cases, Robbins v. California and New York v. Belton, the Supreme Court of the United States established standardized rules for determining when police may conduct a warrantless search of a closed container seized from an automobile. The author analyzes these cases and argues that their holdings do not conform to the policies underlying traditional exceptions to the fourth amendment's warrant requirement. The author suggests that the Supreme Court will probably change these rules when it decides United States v. Ross, a case now pending before the Court.