[1] Police officers, possessing warrants for appellant's arrest, were watching the house where he resided.

The Louisiana Supreme Court, affirming appellant's conviction for possessing heroin, held that the search did not violate the Fourth Amendment, as it occurred "in the immediate vicinity of the arrest" and was "substantially contemporaneous therewith."

[1] Vale demonstrates that courts are not supposed to engage in good faith analysis about search warrant exceptions.

If police officers are wrong and there are no exigent circumstances present, then the search is illegal and the exclusionary rule applies to any collected evidence.

[2] The case distinguished Chimel v. California,[3] in which the Court had held that the warrantless search of a house can be justified as incident to a lawful arrest only if confined to the area within the arrestee's reach, were given retroactive effect.