Supreme Court decisions regarding the Fourth Amendment are arbitrary, unpredictable and often border on incoherent. This quagmire is inspiring Fourth Amendment scholars to develop catch phrases for the chaos. And it is all because of Court attempts to apply the Fourth Amendment in situations where it was never intended to apply - particularly in police search and seizures. The Fourth Amendment was never intended to serve this role.
David E. Steinberg,
Restoring the Fourth Amendment: The Original Understanding Revisited,
33 Hastings Const. L.Q. 47
Available at: https://repository.uchastings.edu/hastings_constitutional_law_quaterly/vol33/iss1/2