On November 27, 1978, Washington, D.C. police detectives received a tip from a reliable source describing a man known as "Bandit" who was selling illegal narcotics stored in the trunk of his car.
After noticing a bullet on the front seat, they searched the glove compartment and discovered a pistol, at which point they arrested the driver, identified as Albert Ross.
Much of this case is derived from the precedent set in Carroll v. United States, 267 U.S. 132 (1925), where the Supreme Court ruled that police officers may make a warrantless search of an automobile if they have probable cause to suspect that it contains contraband.
This particular case dealt with law enforcement officers that tore through the car's upholstery to find illegal liquor in a hidden compartment.
Nearly a decade later, the Court, in California v. Acevedo, 500 U.S. 565 (1991), overturned Arkansas v. Sanders, noting that the decision in the Ross case had already "undermined" it.
Justice Stevens suggests that the parties in the Robbins case had not presented the appropriate arguments that would allow the court to fully consider the issue.
Ultimately, the Court relied most heavily on the original Carroll v. United States precedent instead of the more recent cases.
The Court's ruling in Ross defends that practice: The Court's opinion in this case created some controversy among the dissenting judges when it declared that "The scope of a warrantless search based on probable cause is no narrower - and no broader - than the scope of a search authorized by a warrant supported by probable cause."
The Court's plurality opinion did agree with the Robbins case in that all containers have the same expectation of privacy, whether they are locked briefcases or crumpled paper bags.
It attempts to preclude arguments that certain types of containers are more or less "worthy" of privacy protection than others, poetically stating that "... the most frail cottage in the kingdom is absolutely entitled to the same guarantees of privacy as the most majestic mansion" (derived from an earlier Supreme Court quote which was in turn attributed to William Pitt).
Justice Marshall quoted a previous court opinion to illustrate this: Justice Marshall suggested that the court's opinion goes a step further than the Carroll v. United States case on which it is based, since the Carroll case "did not suggest that the search could be as broad as a magistrate could authorize upon a warrant."
Furthermore, unlike detaining an entire vehicle and driver, seizing a package inside of the car to await a magistrate is not impractical.