In the case of Eberlein v. United States in 1921, the Supreme Court ruled on a matter concerning bankruptcy proceedings and their intersection with criminal law. The petitioner, Eberlein, was charged with perjury for making false statements during his bankruptcy proceedings. He argued that he should not be held criminally liable because he had been granted immunity under section 7a of the Bankruptcy Act which protects individuals from prosecution based on any evidence disclosed during such proceedings. However, the court disagreed and upheld his conviction stating that this provision does not grant absolute immunity but only prevents use of disclosed information as evidence in subsequent criminal prosecutions; it doesn't protect an individual who voluntarily gives false testimony under oath. Therefore, Eberlein's act constituted perjury independent of his bankruptcy proceeding.

In the dissenting opinion for Eberlein v. United States, it was argued that the defendant's Sixth Amendment rights were violated due to his inability to confront witnesses against him. The case involved a man who had been convicted of mail fraud based on evidence from letters he had written and sent through the postal service. The majority ruled that these letters could be used as evidence without violating his right to confrontation because they were considered non-testimonial hearsay - statements made outside of court presented for their truthfulness. However, in disagreement with this ruling, the dissenting justices contended that using these letters as proof without allowing cross-examination infringed upon Eberlein's constitutional rights under the Confrontation Clause of the Sixth Amendment which guarantees defendants in criminal cases have an opportunity to face their accusers and challenge their testimony.