In the United States v. Massei case of 1957, the Supreme Court ruled in favor of the defendant, Joseph Massei. The issue at hand was whether or not a jury could infer guilt from an accused's false explanations about their actions without any direct evidence linking them to a crime. The court held that while it is permissible for juries to consider false statements as indicative of consciousness of guilt, there must be substantial independent evidence establishing that a crime has been committed before such inference can be drawn. Massei had been convicted by lower courts for evading income tax payments based on his unexplained increase in net worth and expenditures over several years which he couldn't account for with his reported income. However, no direct proof was presented showing specific items of taxable income received by him but not reported. The Supreme Court reversed these convictions stating that circumstantial evidence alone cannot support an inference both that a taxpayer willfully understated his gross income and also correctly identified the source thereof unless some foundation connecting the taxpayer with such source has first been laid.

In the dissenting opinion for United States v. Massei, Justice Brennan disagreed with the majority's interpretation of circumstantial evidence in this case. He argued that it was not enough to simply believe that a reasonable hypothesis could be drawn from the facts presented; rather, he believed that all possible hypotheses should have been considered and rejected before reaching a guilty verdict based on circumstantial evidence alone. In his view, if there is any reasonable hypothesis other than guilt which can be derived from the facts, then a conviction cannot stand. He also criticized what he saw as an inconsistency in how different types of evidence were treated by courts - direct versus indirect or circumstantial - arguing they should hold equal weight when determining guilt or innocence.