In Florida v. White (White II), the United States Supreme Court brushed aside the Fourth Amendment’s Warrant Clause and held that the seizure of Tyvessel Tyvorus White’s vehicle in a public place pursuant to the Florida Contraband Forfeiture Act did not violate the Fourth Amendment’s proscription against warrantless searches and seizures. Police officers seized the vehicle two months after White was observed delivering cocaine from the car. On remand, the Florida Supreme Court in White v. State (White III) ignored a good portion of its earlier opinion in which it found that the warrantless seizure of White’s car pursuant to the Florida Contraband Forfeiture Act violated state constitutional due process principles.

In upholding the warrantless seizure of White’s car, the White II majority did not require the State to provide any compelling reasons for the warrantless seizure.