In the case of Michigan v. Nolan K. Lucas (1990), the Supreme Court ruled on whether a state could impose additional penalties for crimes committed while in possession of a firearm, even if that crime was already punishable under federal law. The defendant, Nolan K. Lucas, had been convicted in Michigan state court for possessing a firearm during the commission of a felony and was sentenced to two years' imprisonment - this sentence was to be served consecutively with any other term of imprisonment imposed for conviction of that felony. However, Lucas argued that his prosecution by both federal and state authorities violated the Double Jeopardy Clause which protects against multiple punishments for the same offense. The Supreme Court disagreed with Lucas's argument and upheld his conviction and sentence from Michigan State court ruling 7-2 in favor of Michigan State prosecutors. The majority opinion held that because Congress did not intend to preclude states from imposing their own additional penalties on those who violate their laws while armed, there is no violation of double jeopardy protections when someone is punished separately by both federal and state jurisdictions.

The dissenting opinion in the case of Michigan v. Nolan K. Lucas argued that the majority's decision to uphold a warrantless search and seizure was an overreach, violating Fourth Amendment protections against unreasonable searches and seizures. The dissent contended that there were no exigent circumstances justifying such a violation of privacy rights, as law enforcement had ample opportunity to secure a warrant before conducting their search. Furthermore, they disagreed with the majority's interpretation of "plain view" doctrine; arguing it should not be expanded to include situations where officers deliberately maneuver themselves into positions where they can see evidence without first obtaining a warrant. They also expressed concern about potential abuse by police who could exploit this ruling for unjustified intrusions into private property under guise of routine checks or minor infractions.