In the United States v. Sampson case of 1902, the Supreme Court ruled on an issue related to maritime law and salvage rights. The dispute arose when a British vessel named "Strathgyle" was abandoned by its crew during a storm in international waters and later discovered by Captain Sampson of the American ship "Pensacola". Despite being aware that another ship had already claimed salvage rights, Sampson took control of Strathgyle with his own crew and brought it to port in San Francisco. The original salvors sued for their rightful claim which led to this court case. In its decision, the Supreme Court held that under international maritime law, once a party has taken possession of an abandoned vessel with intent to save it (known as 'salvage'), no other party can interfere unless they are incapable or unwilling to complete the task themselves. Thus, since there was no evidence suggesting incapability or unwillingness from initial salvors before Pensacola's intervention, Captain Sampson’s actions were deemed unlawful interference with prior salvage operations.

The dissenting opinion in the United States v. Sampson case argued that the majority's decision to uphold a conviction based on evidence obtained through a warrantless search was fundamentally flawed. The dissent contended that such an approach violated the Fourth Amendment, which protects citizens from unreasonable searches and seizures. They believed that allowing this kind of evidence would set a dangerous precedent, undermining constitutional protections and potentially leading to abuses of power by law enforcement officials. Furthermore, they disagreed with the majority's interpretation of "exigent circumstances," arguing it was too broad and could be used to justify virtually any warrantless search under certain conditions. In their view, only clear instances where obtaining a warrant is not possible due to immediate danger or risk should qualify as exigent circumstances.