In the case of Jones v. United States in 1959, the U.S. Supreme Court ruled that a defendant could not be convicted for possession of narcotics unless it was proven beyond reasonable doubt that they knew what they were possessing was indeed a narcotic substance. The court also held that mere ownership or control over premises where drugs are found is insufficient to establish guilt without additional evidence linking the accused to the contraband. This decision arose from an appeal by Robert Eugene Jones who had been convicted on charges of illegally possessing and facilitating illegal drug trade after heroin was discovered in an apartment he occasionally used but did not own or rent exclusively himself.

In the dissenting opinion for Jones v. United States, Justice Frankfurter argued that the majority had overstepped its bounds by expanding Fourth Amendment protections to include individuals who are merely present on a property without having any legitimate expectation of privacy or possessory interest in it. He contended that such an expansion was not supported by historical precedent and could lead to potential abuses of this constitutional protection. Furthermore, he disagreed with the majority's assertion that possession of contraband alone is enough to establish standing for challenging a search and seizure; instead, he believed there should be some additional connection between the defendant and the premises searched. In his view, allowing anyone present at a location during an illegal search to challenge it would open up floodgates for challenges from mere visitors or passersby who have no real stake in protecting against unreasonable searches at those locations.