William Oliver Nicholas, Appellant v. the State of Texas, Appellee

Summary

The Court reversed the conviction and remanded because the warrantless seizure of photographic negatives was not justified as a search incident to arrest nor under the plain view doctrine, rendering the evidence inadmissible. The Court applied Chimel's immediate‑control rule and the Supreme Court's plain‑view limitations, finding the officers’ deliberate examination exceeded lawful bounds. Justice Roberts, concurring, agreed with the reversal but argued the majority’s discussion of the taint was unnecessary.