In the 1903 case of Adams v. New York, the U.S. Supreme Court upheld a decision by lower courts that allowed for the seizure and destruction of lottery tickets sent through mail as part of an anti-gambling enforcement effort in New York State. The plaintiff, Adams, argued that this action violated his Fourth Amendment rights against unreasonable searches and seizures because there was no warrant involved in seizing his property (the lottery tickets). However, the court ruled that since lottery tickets were deemed illegal contraband under state law at the time, their possession constituted a crime and thus they could be seized without violating constitutional protections against unlawful search or seizure. This ruling reinforced states' powers to regulate gambling within their borders.

In the dissenting opinion for Adams v. New York, Justice Harlan argued that the Fourth Amendment's protection against unreasonable searches and seizures should extend to state actions as well. He believed that this case was a clear violation of those protections, with police officers seizing books from a private residence without any evidence or suspicion of criminal activity. The majority ruling held that these actions were permissible under state law and did not violate federal constitutional rights; however, Justice Harlan disagreed strongly with this interpretation. He asserted that if such practices were allowed to continue unchecked by the courts, it would undermine citizens' fundamental rights and liberties guaranteed by the Constitution.