The Single-Purpose Container Exception: A Logical Extension of the Plain View Doctrine Made Unworkable
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This Comment examines the single-purpose container exception to the Fourth Amendment's warrant requirement. Since the exception was recognized in Arkansas v. Sanders and revisited in Robbins v. California, the federal circuits have not agreed as to what evidence courts can consider when deciding whether or not to apply the exception to a particular container. While some circuits allow specialized police knowledge and the circumstances surrounding the container's discovery to be considered, most disallow this evidence in making the same determination. As a result, the continued use of the single-purpose container exception results in an inconsistent application of the Fourth Amendment to similarly-situated containers. This Comment concludes that, because of these inconsistencies, the single-purpose container exception should be invalidated or at least limited significantly in order to protect the Fourth Amendment's integrity.