The Sanders conviction was overturned by the Court on the contention that Federal officers, although having probable cause to detain and the authority to search the taxi Sanders was riding in, had unlawfully searched Sanders' suitcase, which contained a large amount of marihuana. The taxi carrying Sanders could be lawfully searched under the 'Carroll Rule' (Carrol v. the United States), a decision which allowed warrantless search of automobiles under two circumstances: (1) probable cause to believe an autombile contains evidence of contraband, and (2) the mobility of the vehicle, making it impractical to require a warrant since the automobile could be moved to a different location. A second decision, United States v. Chadwick, ruled that a footlocker, an item of movable personal property, could not be searched under the Carroll Rule even though it was in an automobile. The automobile is subject to many types of regulatory controls and has transportation as a primary function. A footlocker, on the other hand, is a repository of personal good. Thus the owners' expectations of privacy for its contents are greater. Later cases upheld the privacy principle for various types of containers traveling within automobiles. In Sanders, the holding was narrowly confined to 'personal luggage.' Overall, the Sanders decision creates greater difficulties for law enforcement and courts. The implication is that officers are safer obtaining a warrant for a container search even if they can lawfully search the automobile in which the container rides. While being arrested the suspect can be required to bring the container so that a warrant can be obtained. If an arrest is not possible, the suspect can be detained until a warrant can be sought. The Sanders decision is not all-inclusive, however. The nature of the container and its condition can affect the privacy expectations principle, as can 'special exigencies;' i.e., factors allowing the search under exceptions other than the automobile exemption. Footnotes are provided.