In Irvine v. California, the U.S. Supreme Court was asked to consider whether evidence obtained through an illegal search and seizure could be used in a state court trial. The case involved Paul Irvine who had been convicted of bookmaking based on evidence that police officers had illegally seized from his home without a warrant or consent. In a 5-4 decision, the Court upheld Irvine's conviction stating that while the methods employed by law enforcement were unconstitutional under the Fourth Amendment, this did not necessarily mean that all evidence obtained in such manner should be excluded from state trials as it would undermine effective law enforcement. This ruling stood until 1961 when it was effectively overruled by Mapp v. Ohio which established that "all evidence obtained by searches and seizures in violation of Constitution is...inadmissible in a state court."

In the dissenting opinion for Irvine v. California, Justice William O. Douglas argued that the majority's decision was a departure from precedent and undermined Fourth Amendment protections against unreasonable searches and seizures. He contended that evidence obtained through an illegal search should not be admissible in court, regardless of its relevance or reliability. In this case, police had repeatedly invaded Irvine's home without a warrant to plant listening devices; Douglas believed this constituted an egregious violation of privacy rights protected by the Constitution. Furthermore, he criticized his colleagues for failing to apply federal standards to state cases involving constitutional rights - a practice he felt would lead to inconsistent interpretations of law across states and erode citizens' trust in their legal system.