The case in which the “Ross Anomaly” was resolved was the case of California v. Acevedo. This case, decided in 1991, resolved the anomaly that had been created in United States v. Ross, decided in 1982.
The anomaly had to do with search warrants and the contents of automobiles. It had been held before Ross that police needed a search warrant to search a closed container that happened to be in a vehicle. For example, if the police believe that Mr. X has drugs in his suitcase, and the suitcase is in his car, the police need a warrant to search it. In Ross, the Court held that, if the police had probable cause to search a car they had legally stopped, they could search anything in that car that could hold what they were looking for without a warrant. So, in other words, if Mr. X’s car were stopped and the police had probable cause to suspect he had drugs with him, they could search his suitcase without a warrant. Thus, there was an anomaly: in one sense, it was illegal to search the suitcase without a warrant, but in another sense it was legal to do so.
In Acevedo, the Court resolved this anomaly. In that case, the Court made it easier to search closed containers in cars. They announced that
The police may search an automobile and the containers within it where they have probable cause to believe contraband or evidence is contained.