Search and Seizure of Containers Found in Automobiles: The Supreme Court Struggles for a "Bright Line" Rule

Two recent decisions by the United States Supreme Court have added a new dimension to the law of search and seizure of automobiles and containers found within motor vehicles. The plurality opinion in Robbins v. California'held that a closed opaque container found in the luggage compartment of a station wagon during the course of a lawful vehicle search could not be seized without a warrant. However, in New York v. Belton, a majority held that a police officer, incident to a lawful custodial arrest of an occupant of an automobile, may search the passenger compartment of that automobile and examine contents of any containers, open or closed, found therein.