In the case of Patterson, General Administrator, et al. v. United States (1958), the U.S Supreme Court ruled on a dispute involving federal estate tax law and state property rights. The issue at hand was whether certain assets transferred by a decedent before death should be included in his gross estate for federal taxation purposes under Section 811(c) of the Internal Revenue Code of 1939. The decedent had transferred securities to his wife but retained life income from them until his death; he also reserved power to revoke or alter beneficiaries' interests therein without their consent. The court held that these transfers were indeed includable in the gross estate because they fell within "transfers...intended to take effect in possession or enjoyment at or after" the transferor's death as per Section 811(c). This decision affirmed that federal tax laws supersede state property rights when determining what constitutes an individual's taxable estate upon their demise.

In the dissenting opinion for Patterson v. United States, Justice Frankfurter argued that the majority's decision to uphold a conviction based on evidence obtained through an unlawful search and seizure was in direct violation of Fourth Amendment rights. He contended that by allowing such evidence to be used in court, it would encourage law enforcement officers to continue engaging in unconstitutional practices with impunity. Furthermore, he expressed concern over the potential erosion of civil liberties if this precedent were allowed to stand unchallenged. In his view, upholding constitutional protections should take precedence over securing convictions at any cost.