In 1987, the Supreme Court answered this question in Arizona v. Hicks, holding that the fourth amendment requires that there must be probable cause to invoke the plain view doctrine and thereby strengthening the rights of individuals against unreasonable searches and seizures. The article reports the facts of the Hicks case, the lower court holdings, and the reasoning of the U.S. Supreme Court on the issue of the plain view exception of the fourth amendment. The decision was important for several reasons. First, it established guidelines for all courts to use in analyzing the plain view exception to the fourth amendment. Second, it provided guidance for police officers who must conduct plain view searches, and third, it dismisses the need for general exploratory searches and deters unreasonable searches. 130 footnotes.