Effectively, the decision overruled the previous distinction in Chadwick-Sanders that held such a search of containers in automobiles required a warrant even if there was probable cause for the search. In U.S.A vs. Chadwick 433 U.S. 1 (1977), it was held that in the absence of exigency, searching double-locked luggage inside an automobile is not justified and violates the Fourth Amendment rights. Here, it was explained that luggage may be movable just like the automobile but is not subjected to lesser privacy expectations associated with the automobile. Therefore, the police cannot search personal effects that they confiscate during an arrest if they do not have a warrant to perform the search. In U.S.A vs. Johnson 457 U.S. 537 (1982), the defendant claimed that his written and oral confessions were the results of an unlawful arrest that could not be supported by probable cause. However, it was held that the warrantless arrest of Johnson in his home did not violate his Fourth Amendment rights because there was probable cause for the arrest and the confessions admitted as evidence. However, this decision was later overruled after Payton v New York 445 U.S. 573 was decided and it was ruled the respondent’s Fourth Amendment rights were violated.
The similarity in the three cases is the issue of warrantless search and presenting the evidence found to the court during prosecution. However, basing on the different facts f the cases, different verdicts were made. Both U.S.A. vs. Acevedo and U.S.A. vs. Johnson held that the police did not require warrants to search the automobile and home respectively. The reasoning is that they had probable cause to believe there was evidence in the automobile and home that would link the suspects to crime. More specifically in U.S.A. vs. Acevedo, the most relevant holding was that the police could search the entire automobile and any closed containers in it.