Arkansas v. Sanders
In Arkansas v. Sanders (1979) 442 U.S. 753, the United States Supreme Court held that, absent exigent circumstances, a warrant is generally required to search closed containers removed from an automobile properly stopped in the field and searched for contraband.
The court declared, however, that "not all containers and packages found by police during the course of a search will deserve the full protection of the Fourth Amendment. Thus, some containers (for example a kit of burglar tools or a gun case) by their very nature cannot support any reasonable expectation of privacy because their contents can be inferred from their outward appearance. Similarly, in some cases the contents of a package will be open to 'plain view,' thereby obviating the need for a warrant." (442 U.S. at p. 764, fn. 13.)
The court discussed the relevant principles and noted: "The Fourth Amendment protects the privacy and security of persons in two important ways. First, it guarantees 'the right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures.' In addition, this court has interpreted the amendment to include the requirement that normally searches of private property be performed pursuant to a search warrant issued in compliance with the warrant clause. " ( Id., pp. 757-758.)