This article assesses the extent to which United States v. Ross indeed orders chaos and charts an unequivocable and desirable course for the law of vehicular searches under the fourth amendment. After focusing on Ross and its predecessor cases in the context of the automobile exception, the article assesses the broader import of Ross as a possible harbinger of a retreat from the general requirement for warrants to search personal effects, whether or not associated with automobiles, and recommends ways to avoid such a retreat.

I. Introduction

II. The Automobile Exception: Pre-Ross Cases ... A. The Automobile Search Doctrine ... B. The Container Search Doctrine

III. The Ross Case ... A. The Facts ... B. The Holding ... C. Rationale ... D. The Dissent

IV. Ross: Analysis and Critique ... A. Ross: Persuasiveness of the Rationale ... B. Ross: Justified Bright Line or Untenable Departure from Constitutional Principle? ... 1. The Necessity for the Ross Rule ... 2. Ross as a Bright Line ... 3. Ross as Subject to Manipulation and Abuse ... 4. Secondary Values of Ross

V. Beyond Ross: The Future of the Warrant Requirement in Container Searches ... A. Ross and Prior Case Law ... B. Recommendations

VI. Conclusion