In the case Earthy D. Daniels, Jr. v. United States (2000), the U.S Supreme Court examined whether a defendant's prior conviction for escape from a halfway house was considered as a "crime of violence" under federal sentencing guidelines and therefore could be used to enhance his sentence for subsequent offenses. The court ruled that an escape from custody is inherently dangerous and potentially violent, even if no actual violence occurred during the act itself or it involved only minimal confrontation with authorities such as in this case where Daniels had walked away from an unsecured correctional facility without permission. The decision meant that any form of escape would be classified as a crime of violence due to its potential risk of causing harm or danger to others regardless of how it was carried out, thus allowing judges greater discretion in imposing harsher sentences on repeat offenders who have previously escaped custody.

In the dissenting opinion for Earthy D. Daniels, Jr. v. United States, it was argued that the majority's decision to uphold a conviction based on evidence obtained through an allegedly unconstitutional search and seizure was incorrect. The dissenters believed that law enforcement officers violated Daniels' Fourth Amendment rights when they searched his home without a warrant after he had been arrested outside of it. They contended that this action did not fall under any recognized exceptions to the warrant requirement, such as exigent circumstances or consent given by someone with authority over the premises being searched. Furthermore, they disagreed with the majority's view that even if there were constitutional violations in this case, suppression of evidence would be inappropriate due to good faith reliance on binding appellate precedent by police officers at time of their actions.