This finding reversed previous Supreme Court decisions such as Boyd v. United States which had held that search warrants may not be used as a means of gaining access to a man's house or office and papers solely for the purpose of making search to secure evidence to be used against him in a criminal or penal proceeding...[1] In the morning of March 17, 1962, an armed man robbed the Diamond Cab Company in Baltimore, Maryland.

A search of the premises revealed a gun and clothing, found in a washing machine, that matched the description of the armed man that had been reported by the cab company.

However, the appellate court held that the clothing was of 'mere evidential' nature, not in plain sight, and this was not properly seized.

However, under the rules at that time, seizing evidence such as the clothing that fit the description of the fleeing robber would not have been allowed.

Suppressing the improperly seized evidence would lead to a new trial under the principle of the fruit of the poisonous tree.