The Gibson v. United States case in 1896 revolved around the issue of whether a U.S. citizen could renounce his citizenship and then claim protection from the U.S. government while residing in another country, specifically Japan, where he had become a subject. The plaintiff, William Gibson, was born in California but moved to Japan where he became a naturalized citizen and swore allegiance to the Emperor of Japan. Later on, Japanese authorities seized property belonging to him which led him to seek help from American diplomatic representatives based on his birthright citizenship status. However, the Supreme Court ruled against Gibson stating that by voluntarily becoming a naturalized citizen of another nation and swearing allegiance to its sovereign ruler; one effectively relinquishes their rights as an American Citizen including any protections or privileges associated with it abroad unless they have been pardoned by Congress or re-naturalized under US law.

In the dissenting opinion for Gibson v. United States, the justice 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 Fourth Amendment rights. The justice contended that by allowing such evidence to be used in court, it effectively condones illegal actions by law enforcement officials. This not only undermines citizens' constitutional protections but also erodes public trust in legal institutions. Furthermore, it sets a dangerous precedent where police misconduct is rewarded rather than punished, thus incentivizing further violations of civil liberties under the guise of criminal investigations. Therefore, according to this dissenting view, any evidence obtained unlawfully should be deemed inadmissible regardless of its relevance or impact on a case's outcome.