United States v. Chadwick, 433 U.S. 1 (1977), was a decision by the United States Supreme Court, which held that, absent exigency, the warrantless search of double-locked luggage just placed in the trunk of a parked vehicle is a violation of the Fourth Amendment and not justified under the automobile exception.
The holding in Chadwick that a search incident to arrest must not be too remote in time or place is still good law.
Respondents had recently stepped off a train and were putting a suitcase into the trunk of a car when they were stopped by federal agents.
Federal agents had probable cause to arrest the respondents and to believe that the suitcase contained narcotics.
About an hour and a half after the arrest, the agents opened and searched the suitcase without a warrant.