In Dowling v. United States, the Supreme Court ruled in favor of Paul Edward Dowling who was convicted for interstate transportation of stolen property - specifically, bootleg vinyl records. The court held that a violation of copyright does not necessarily equate to theft under the National Stolen Property Act (NSPA). The NSPA requires goods to be physically obtained by fraud or theft and then transported across state lines. In this case, while Dowling had infringed on copyrights by producing unauthorized copies of music recordings, he did not steal physical items before transporting them. Therefore, his actions did not fall within the purview of the NSPA as per majority opinion written by Justice Thurgood Marshall.

In the dissenting opinion for Dowling v. United States, Justice White argued that the majority's interpretation of the law was too narrow and failed to adequately consider Congress' intent in drafting it. He contended that Congress intended to criminalize all forms of theft involving interstate commerce, not just those involving physical property. This would include intellectual property such as copyrighted material. Furthermore, he disagreed with the majority's assertion that a conviction under this statute required proof beyond a reasonable doubt that stolen goods were physically transported across state lines; instead, he believed it sufficient to show they had been used in some way affecting interstate commerce. Lastly, Justice White criticized the majority for ignoring precedent which supported his broader interpretation of federal theft laws.