In Robbins v. California (1981) 453 U.S. 420, defendant's station wagon was stopped by California Highway patrol officers for his erratic driving. When defendant opened the door to obtain his registration, an officer smelled marijuana smoke. The officer then searched the passenger compartment, discovering marijuana and equipment for its use. Upon opening the tail gate and the luggage compartment immediately within, they observed a tote bag containing wrapped packages. The packages were opened, disclosing substantive quantities of marijuana. The California Court of Appeal upheld the search, based upon a finding of reasonable cause to believe the compartment contained contraband and that the appearance of the packages identified them as containing marijuana. Reversing, the Supreme Court noted that precedent in United States v. Chadwick, 399 U.S. 1, and Arkansas v. Sanders (1979) 442 U.S. 753, gave constitutional protection to containers taken from automobiles and that no distinction should be drawn among the types of containers except those that by their very nature reveal their contents (e.g., a kit of burglary tools or a gun case) or whose contents are in plain view (e.g., because the package is open). It found the packages containing the marijuana not to reveal their contents.