Arkansas v. Sanders

Arkansas v. Sanders was a 1979 decision by the United States Supreme Court which held that, absent exigency, the warrantless search of personal luggage merely because it was located in an automobile lawfully stopped by the police is a violation of the Fourth Amendment and not justified under the automobile exception. Similar to United States v. Chadwick, the luggage was the subject of police suspicion before being placed in the vehicle.

Sanders resolved two distinct lines of cases: on the one hand, Carroll v. United States laid down the automobile exception which allowed for warrantless searches of automobiles; on the other hand, Chadwick did not allow for a warrantless search of luggage. Sanders declined to extend the automobile exception here, again stressing, as in Chadwick, the heightened expectation of privacy in one's luggage.