The 11^th Circuit Court in Florida determined whether the seizure of a suspect’s luggage was in violation of his Fourth Amendment rights. The court in United States v. Puglisi held that this type of seizure was permissible if there was “an articulable suspicion” that there was contraband in the luggage.

However, the court also held that the 140 minutes that the luggage was seized amounted to more than a brief detention. Therefore, the court held that there needed to be probable cause for the seizure. The court opined that a 35 minute seizure would have been an acceptable and permissible time to hold the luggage.