Results indicate that following Stewart's departure in 1981, reasonability became the preferred approach to such cases. Between 1975 and 1981, the categorical approach was used to decide 23 cases; while reasonableness was employed in only 8. After 1981, 20 cases were decided on the reasonableness standard; while 18 were decided using the categorical approach. Between 1984 and 1988, 19 cases employed reasonableness; while 10 employed the categorical approach. Further, with the ascendance of the standard of free-form reasonability, more warrantless searches and seizures were approved. Since Stewart's retirement, the Court has excluded evidence from a warrantless search or seizure in only 23.7 percent of the cases it has reviewed. Factors possibly contributing to this change in perspective are considered. An index of cases and a comment are included. 45 footnotes.