In Harris v. United States (1946), the U.S Supreme Court upheld a conviction for knowingly possessing counterfeit money, despite the defendant's claim that he was unaware of its fraudulent nature. The court ruled that possession of a large amount of counterfeit currency, in this case $10,000 worth, is enough to infer knowledge and intent to defraud unless there is evidence presented by the defense to suggest otherwise. This ruling established an important precedent regarding burden shifting in criminal cases: while it remains on prosecution initially to prove guilt beyond reasonable doubt; once they establish certain facts suggesting guilt (such as possession of significant amounts of counterfeit money), it can shift onto defendants who must then provide plausible innocent explanations or risk being found guilty based on those unexplained incriminating circumstances.

In the dissenting opinion for Harris v. United States, Justice Frank Murphy argued that the majority's decision undermined Fourth Amendment protections against unreasonable searches and seizures. He contended that allowing police to seize evidence without a warrant during an arrest not directly related to the crime in question was a dangerous expansion of law enforcement powers. In his view, this could lead to abuses where police might arrest someone on minor charges as an excuse to search for evidence of more serious crimes without obtaining a warrant first. He also disagreed with the majority's interpretation of "reasonable" seizure, arguing it should be limited only to items directly related or instrumentalities of the crime for which one is arrested rather than any criminal activity generally.