Until 1967, a search was an all-or-nothing concept. Either it was a search subject to the probable cause and warrant requirements or it was not a search. This situation often was referred to as the:

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The term "bright-line approach" refers to a clear, straightforward rule or standard, consisting of objective criteria that can be easily applied without much ambiguity. In the context of searches until 1967, the law was seen as having a clear demarcation: either an action was considered a search, requiring probable cause and a warrant, or it was not considered a search at all. This clear distinction is why it was referred to as the bright-line approach.

Until 1967, a Search Was an All-Or-Nothing Concept