In Santoro v. United States (1967), the U.S Supreme Court ruled on a case involving an individual who had been convicted of transporting stolen vehicles across state lines, in violation of the Dyer Act. The defendant, Mr. Santoro, argued that his conviction should be overturned because he was not informed by law enforcement officials that he had a right to remain silent and consult with an attorney before making any statements during questioning - rights protected under Miranda v. Arizona (1966). However, the court held that since Mr. Santoro's arrest and subsequent interrogation occurred prior to the decision in Miranda v. Arizona, its ruling did not apply retroactively to his case; thus upholding his conviction.

In the dissenting opinion for Santoro v. United States, Justice Douglas argued that the majority's decision to allow evidence obtained through a deceptive police tactic was inconsistent with previous Supreme Court rulings and undermined constitutional protections against self-incrimination. He contended that when law enforcement officers misrepresent themselves in order to obtain incriminating statements, they are essentially coercing those statements out of individuals who may not fully understand their rights or the situation at hand. This type of coercion, he believed, violated an individual's Fifth Amendment right against self-incrimination and should therefore be considered unconstitutional. Furthermore, he expressed concern about the potential implications of this ruling on future cases involving police deception and coercion tactics.