This Note analyzes the development of these warrantless container search and seizure exceptions to furnish a comprehensive review of their justifications. The major focus is on the underlying rationale of Belton and Ross and the possible ramifications of such far-reaching warrant exceptions. The Note recommends that state courts interpret their state constitutions to allow the less drastic alternative of warrantless seizures of certain containers rather than warrantless searches as permitted by Belton and Ross under the federal Constitution. In addition, an analytic methodology for isolating interrelated yet distinct search and seizure questions is proposed. Initially, a general background of fourth amendment jurisprudence is set forth to illustrate the Court's continuous struggle with search and seizure problems.
Note, Robbins, Belton and Ross: Reconsideration of Bright Line Rules for Warrantless Container Searches, 31 Clev. St. L. Rev. 529 (1982)