In the case of Chappell v. United States in 1895, the U.S Supreme Court ruled on a matter concerning copyright law. The plaintiff, William A. Chappell, had copyrighted five books of music under one title and later sold them separately without any indication that they were part of a larger collection. When another party began selling similar individual sheets of music, Chappell sued for copyright infringement. The court held that since each sheet was not individually marked with its own copyright notice (as required by law at the time), it did not enjoy separate protection under the original collective work's copyright registration; therefore no violation occurred when others reproduced individual pieces from this collection. This decision clarified an important aspect regarding how copyrights apply to collections or compilations: if parts are intended to be used independently and do not carry their own notices, they may lack protection afforded to whole works.

In the dissenting opinion for Chappell v. United States, Justice Harlan disagreed with the majority's decision to uphold a conviction based on evidence obtained through an unauthorized search and seizure. He argued that such actions violated the Fourth Amendment rights of citizens, which protect against unreasonable searches and seizures without probable cause or a warrant issued by a judge. In his view, allowing this kind of evidence to be used in court would undermine these constitutional protections and could lead to abuses of power by law enforcement officials. Furthermore, he believed that it was not enough for courts simply to disapprove of illegal methods; they must also refuse to accept any results gained from them in order to deter future violations.