In Byars v. United States (1926), the U.S. Supreme Court ruled that a search warrant, which was issued for certain items but used to seize other unrelated items, violated the Fourth Amendment's protection against unreasonable searches and seizures. The case involved federal prohibition agents who accompanied local police during a raid on an illegal distillery operation in Kansas City, Missouri. While there, they seized ledgers not specified in the original warrant that were later used as evidence of tax evasion charges against William Byars. The court held that this constituted an unlawful expansion of the scope of the search beyond what was authorized by the warrant and thus infringed upon Byar’s constitutional rights.

In the dissenting opinion for Byars v. United States, Justice Oliver Wendell Holmes Jr. argued that the search warrant used by federal officers was valid under Ohio law and therefore should not have been deemed unconstitutional. He contended that since state officials had a right to conduct such searches, it would be unreasonable to deny federal agents from doing so when they were acting in conjunction with local authorities. Furthermore, he disagreed with the majority's view that this case represented an intrusion of federal power into state matters; instead, he saw it as cooperation between different levels of government in enforcing laws against illegal alcohol production during Prohibition era. Thus, according to him, there was no violation of Fourth Amendment rights against unreasonable searches and seizures because both sets of officers acted within their respective jurisdictions' legal boundaries.