In the case of Knewel, Sheriff v. Egan in 1924, the U.S Supreme Court was tasked with determining whether a state law that allowed for an arrest without a warrant violated the Fourth Amendment's protection against unreasonable searches and seizures. The defendant, Egan, had been arrested by Sheriff Knewel under this state law after being suspected of committing burglary. After his conviction in lower court proceedings based on evidence obtained during his arrest, Egan appealed to the Supreme Court arguing that his constitutional rights were violated due to lack of proper search warrant at time of arrest. The Supreme Court ruled in favor of Egan stating that while states have some discretion over their own criminal procedures they cannot infringe upon federally protected constitutional rights such as those provided by Fourth Amendment. Therefore it held that arrests made without warrants are unconstitutional unless there is probable cause or exigent circumstances justifying immediate action from police officers.

In the dissenting opinion for Knewel, Sheriff v. Egan, it was argued that the court majority had overstepped its boundaries by deciding on a matter of state law rather than focusing solely on federal issues. The dissenting justices believed that the question of whether or not an officer could be held personally liable for damages resulting from enforcing an unconstitutional statute should have been left to state courts to decide. They pointed out that there were no clear precedents in federal law regarding this issue and thus felt it inappropriate for the Supreme Court to establish one without proper jurisdiction. Furthermore, they expressed concern about potential negative consequences of such a decision, including discouraging public officials from performing their duties due to fear of personal liability.