In the 1947 case of Sealfon v. United States, the Supreme Court ruled in favor of Samuel Sealfon, who had been accused and acquitted of conspiracy to defraud the U.S. government but was later charged with a substantive offense arising from that same alleged conspiracy. The court held that his second prosecution violated the Double Jeopardy Clause of the Fifth Amendment because it involved essentially identical evidence as used in his first trial for conspiracy charges. The ruling established an important precedent regarding double jeopardy protections: if two offenses are so closely tied together that proof required for one would suffice for another, then they should be considered as one offense under law and cannot lead to separate prosecutions.

In the dissenting opinion for Sealfon v. United States, Justice Frankfurter disagreed with the majority's application of res judicata and collateral estoppel principles to criminal law. He argued that these doctrines were not applicable in this context because they are based on civil litigation concepts which do not translate well into criminal proceedings due to their different objectives and procedures. Furthermore, he contended that applying such doctrines could potentially undermine a defendant's right to a fair trial by preventing them from presenting new evidence or arguments in subsequent trials related to the same alleged crime. Therefore, he believed that each charge against a defendant should be considered independently unless there is explicit legislative intent indicating otherwise.