In the case of Haring v. Prosise, 1982, the U.S. Supreme Court ruled that a guilty plea in a criminal proceeding does not preclude the defendant from asserting his Fourth Amendment rights in a subsequent civil action against police officers for unlawful search and seizure. The plaintiff, Prosise, had pleaded guilty to manufacturing controlled substances after evidence was seized during an allegedly illegal search by Arlington County Police Department officers. Later on he filed a civil suit claiming damages due to violation of his constitutional rights under Section 1983 of Title 42 of United States Code (Civil Rights Act). The Virginia courts dismissed his claim stating that he could not challenge the legality of the search because he had already admitted guilt in criminal proceedings which implicitly accepted lawfulness of obtained evidence. However, upon reaching Supreme Court it held that since no state court determined whether or not there was consent for this particular search and seizure incident while accepting Prosise's guilty plea; therefore it did not constitute issue preclusion (or collateral estoppel) preventing him from raising this matter again in federal court.

In the dissenting opinion for Haring v. Prosise, 1982, Justice Rehnquist disagreed with the majority's view that a guilty plea does not preclude a defendant from later asserting constitutional claims in a civil action under Section 1983. He argued that allowing such actions would undermine the finality of judgments and disrupt efficient judicial administration by encouraging defendants to strategically withhold constitutional objections during criminal proceedings only to raise them later in civil suits. Furthermore, he contended that this approach could lead to inconsistent verdicts if different juries reached divergent conclusions about the same underlying facts or legal issues. Finally, he expressed concern about potential abuse of process and manipulation of court procedures by litigants seeking tactical advantages rather than genuine vindication of their rights.