In the case of Sweeney, Sheriff v. Woodall in 1952, the United States Supreme Court addressed a dispute over whether or not a sheriff could be held liable for damages caused by his deputies' actions. The plaintiff, Woodall, argued that he was unlawfully arrested and detained by two deputy sheriffs who were acting under orders from Sheriff Sweeney. He sought compensation for false imprisonment and assault from both the deputies and their superior officer. The court ruled in favor of Sheriff Sweeney stating that while an employer can generally be held responsible for employees’ actions performed within their scope of employment (under respondeat superior), this principle does not apply to public officials like sheriffs unless they directly ordered or participated in the wrongful act. In this case, there was no evidence suggesting direct involvement or instruction from Sheriff Sweeney regarding Woodall's arrest and detention. Therefore, it was determined that a sheriff cannot be held vicariously liable for unlawful acts committed by his deputies if he did not participate in them nor gave explicit instructions leading to those acts.

In the dissenting opinion for Sweeney, Sheriff v. Woodall, Justice Frankfurter disagreed with the majority's interpretation of due process rights in relation to confessions obtained during police interrogations. He argued that a confession should not be considered voluntary unless it was given freely and without coercion or undue influence from law enforcement officers. In this case, he believed there was evidence suggesting that Woodall's confession may have been coerced by police officers who threatened him with violence if he did not confess to his crimes. Therefore, Frankfurter felt that the court had failed to uphold its duty to protect individuals' constitutional rights against self-incrimination and unfair treatment by law enforcement officials.