In 1973, the United States Supreme Court expanded the authority of law enforcement officers to conduct searches incident to a lawful arrest. In the case before the Court, Willie Robinson was arrested for the crime of operating a motor vehicle with a revoked license. Incident to the arrest, the arresting officer searched Robinson for weapons and found a crumpled cigarette package in Robinson’s clothing. The officer opened the cigarette package and found heroin. The Supreme Court upheld the search and ruled that law enforcement officers may open and search through all items found on the arrestee’s person even if they are in a closed container and and even if the arresting officer has no suspicion that the contents of the container are illegal. United States v. Robinson, 414 U.S. 218 (1973).