In the 1903 case of Buttfield v. United States, the U.S. Supreme Court ruled that a defendant could not be convicted based on evidence obtained through an unlawful search and seizure. The case involved Adelaide Buttfield who was accused of smuggling diamonds into the country from Canada without declaring them to customs officials as required by law. During her trial, she argued that the evidence against her had been unlawfully seized during a warrantless search of her hotel room by customs officers and should therefore be excluded from consideration in court proceedings under Fourth Amendment protections against unreasonable searches and seizures. The Supreme Court agreed with Buttfield's argument, ruling in favor of protecting individuals' constitutional rights over facilitating criminal prosecutions.

In the dissenting opinion for Buttfield v. United States, Justice Harlan argued that the defendant was not given a fair trial due to prejudicial errors made by the lower court. He disagreed with the majority's decision to uphold her conviction on charges of conspiracy and bribery in relation to mining claims. Specifically, he took issue with how evidence was presented during trial; he believed that certain testimonies were improperly admitted which could have influenced jury bias against Buttfield. Additionally, Justice Harlan criticized instructions given to jurors regarding reasonable doubt standards - arguing they were misleading and confusing - potentially leading them towards a guilty verdict without proper consideration of all evidence at hand. Furthermore, he expressed concern over potential violations of constitutional rights as it pertained to self-incrimination protections under Fifth Amendment principles – particularly when considering how testimony from co-conspirators was used against Buttfield despite her objections.