In the 1996 case of United States v. Vernon Watts, the defendant was charged with possession and intent to distribute cocaine base (crack). The issue at hand was whether or not a police officer's warrantless entry into Watt's home violated his Fourth Amendment rights against unreasonable searches and seizures. The Supreme Court ruled that it did not because exigent circumstances justified the officer’s actions. Specifically, when officers arrived at Watts' residence in response to a tip about drug activity, they smelled marijuana emanating from inside and heard noises suggesting evidence might be destroyed if they waited for a search warrant. Therefore, their immediate entry fell under an exception to the requirement for a search warrant due to imminent destruction of evidence.

The dissenting opinion in the United States v. Vernon Watts case argued that the majority's decision to uphold Watts' conviction for using a firearm during and in relation to a drug trafficking crime was incorrect. The dissenters believed that there was insufficient evidence to prove beyond reasonable doubt that Watts had used his gun "during and in relation" to his drug crimes, as required by law. They pointed out that while it is true he possessed firearms at his residence where drugs were found, this alone does not establish use of those weapons in connection with drug trafficking activities. Furthermore, they contended the government failed to show any specific instances where Watts used or intended to use these guns directly related with his illegal activity; hence convicting him on such grounds would be speculative at best. This interpretation could potentially broaden the scope of what constitutes 'use' under federal law which may lead towards unjust convictions based on mere possession rather than actual usage tied specifically with criminal conduct.