In United States v. Jacobsen, 466 U.S. 109 [1984], such action was described as a "seizure" within the meaning of the Fourth Amendment, but the Court held that, in circumstances such as these, "that seizure was not unreasonable." (Id., 466 U.S. at 120.) The Court held that "such containers may be seized, at least temporarily, without a warrant" because "it is well-settled that it is constitutionally reasonable for law enforcement officials to seize 'effects' that cannot support a justifiable expectation of privacy without a warrant, based on probable cause to believe they contain contraband." (Id., at 121-122.)