unconstitutional because the police did not have probable cause to search the vehicles, but rather just the suspect containers which had been placed inside, and they did not have the warrant required to search the containers. Since the police had probable cause to suspect the containers before they came near an automobile, the relationship between the containers and the vehicles were purely coincidental. Since the police did not have probable cause to search the vehicle, they could not take advantage of the "automobile exception" to perform a warrantless search of the containers. From Arkansas v. Sanders: ... Here, as in Chadwick, it was the luggage being transported by respondent at the time of the arrest, not the automobile in which it was being carried, that was the suspected locus of the contraband. The relationship between the automobile and the contraband was purely coincidental, as in Chadwick. (Arkansas v. Sanders, 442 U.S. 753) The Court agreed with most facets of those two cases, stating in the Ross case that: ...the rationale justifying the automobile exception does not apply so as to permit a warrantless search of any movable container that is believed to be carrying an illicit substance and that is found in a public place - even when the container is placed in a vehicle (not otherwise believed to be carrying contraband). (United States v. Ross, 456 U.S. 798) However, the court found that those previous cases did not entirely apply to the situation at hand, because in the case of Ross there was no target container that had been observed being placed in the car, but rather probable cause to believe that contraband was located somewhere in the car. Therefore, there was probable cause to search Ross' car. Nearly a decade later, the Court, in California v. Acevedo, 500 U.S. 565 (1991), overturned Arkansas v. Sanders, noting that the decision in the Ross case had already "undermined" it. The Court's plurality opinion also considered Robbins v. California, 453 U.S. 420 (1981), a case which bore more similarity to the Ross case. In that case, police pulled over a car smelling marijuana smoke, and proceeded to search the car. In the trunk they found two packages wrapped in opaque plastic, which they unwrapped, discovering marijuana inside. The Court ruled that the warrantless search of the vehicle was legal, but the warrantless search of the two packages found within was unconstitutional.