In the United States v. Freel case of 1901, the Supreme Court ruled on a matter involving land rights and mining claims in California. The defendant, Freel, had made two separate mining claims on public lands under federal law - one for gold and another for quicksilver (mercury). However, he was accused by the government of unlawfully encroaching upon these lands without having performed any labor or improvements required to maintain his claim as stipulated by law. The court held that while it is possible to hold multiple valid mineral entries simultaneously if they are distinct from each other in terms of their minerals being sought after; there must be proof that actual work has been done towards extracting those minerals. In this case, no such evidence was provided by Freel hence his claim was deemed invalid leading to him losing possession of both parcels of land.

In the dissenting opinion for United States v. Freel, Justice Harlan argued that the majority's decision to uphold a conviction based on evidence obtained through an unlawful search and seizure was fundamentally flawed. He contended that such actions violated the Fourth Amendment rights of citizens, which protect against unreasonable searches and seizures without probable cause or a warrant issued by a judge. Furthermore, he asserted that allowing illegally obtained evidence to be used in court would incentivize law enforcement officers to disregard constitutional protections in their pursuit of criminal convictions. This could potentially lead to widespread abuses of power and violations of civil liberties. Therefore, Justice Harlan believed that any evidence gained from an illegal search should be excluded from trial proceedings as it is tainted by its unconstitutional origins.