In the case of Dowdell v. United States (1910), the U.S Supreme Court upheld a lower court's decision to convict William Dowdell for perjury. The charges stemmed from false statements he made during his bankruptcy proceedings, where he claimed not to have transferred any property other than what was listed in his schedule of assets and liabilities. Evidence later revealed that Dowdell had indeed transferred some properties without disclosing them in his filings. In its ruling, the Supreme Court held that while it is necessary for an indictment for perjury to state with certainty the substance of false testimony given by a defendant, it is not required to recite all evidence proving falsity or set forth contradictory facts demonstrating untruthfulness. Therefore, even though there were discrepancies between different versions of indictments against him, these did not invalidate Dowdell’s conviction as they sufficiently conveyed allegations about his dishonesty under oath.

In the dissenting opinion for Dowdell v. United States, Justice Harlan argued that the majority's decision to uphold a conviction based on evidence obtained through an unlawful search and seizure was in direct violation of the Fourth Amendment. He contended that allowing such evidence to be used in court would set a dangerous precedent, effectively condoning illegal actions by law enforcement officials and undermining citizens' constitutional rights. Furthermore, he expressed concern over potential abuses of power if this ruling were allowed to stand unchallenged. In his view, it is essential for courts not only to protect individuals from unjust treatment but also maintain public trust in legal institutions by ensuring they operate within their lawful boundaries.