In the United States v. Murray case of 1927, the Supreme Court ruled on an issue related to evidence obtained during a search and seizure operation. The defendant, Murray, was convicted for illegally possessing and selling alcohol during Prohibition after police found liquor in his warehouse without a warrant. His defense argued that this evidence should be excluded because it was obtained unlawfully. However, law enforcement had already gathered enough independent evidence before the illegal search to justify arresting Murray and searching his property legally later on. The Supreme Court held that if police have sufficient information to justify a legal search but instead conduct an illegal one first, any evidence they would have inevitably discovered during the subsequent legal search is admissible in court. This decision established what came to be known as the "independent source doctrine," which allows for certain exceptions to exclusionary rules regarding improperly obtained evidence.

In the dissenting opinion for United States v. Murray, Justice Oliver Wendell Holmes Jr., joined by Justice Louis Brandeis, argued that the evidence obtained during an illegal search should not have been excluded from trial because it was later discovered independently through legal means. They contended that if illegally obtained evidence led to a discovery of additional information or material which would have inevitably been found without said illegal action, then such evidence is admissible in court. The justices believed this approach balanced the need to deter unlawful police conduct with society's interest in prosecuting criminal activity effectively and justly. Their view did not prevail at the time; however, it laid groundwork for what would eventually become known as "the independent source doctrine" and "inevitable discovery rule," both crucial components of modern Fourth Amendment jurisprudence.