In the United States v. Winston case of 1897, the Supreme Court ruled on a matter involving customs duties and importation laws. The defendant, Winston, had imported goods from Canada into Detroit without paying required customs duties by falsely declaring them as domestic products. He was charged under Section 3082 of the Revised Statutes which made it illegal to knowingly make false statements with intent to defraud revenue or evade duty payments. However, he argued that this law did not apply because his actions were already covered by another statute (Section 2864) specifically dealing with smuggling goods into the country. The court held in favor of the government stating that both statutes could be applied simultaneously since they addressed different aspects - one dealt with evasion of payment while other focused on fraudulent entry irrespective of whether any duty was evaded or not. Therefore, even if an act is punishable under more than one statute, each can be enforced separately unless Congress has explicitly provided otherwise.

The dissenting opinion in the United States v. Winston case argued that the majority's decision to uphold a conviction based on evidence obtained through a warrantless search was fundamentally flawed. The dissenters believed this ruling violated the Fourth Amendment, which protects citizens from unreasonable searches and seizures. They contended that allowing such practices would set a dangerous precedent, potentially leading to widespread abuse of power by law enforcement officials who could exploit this loophole to bypass due process rights and invade personal privacy without just cause or proper authorization. Furthermore, they expressed concern about undermining public trust in legal institutions if police were permitted to operate outside constitutional constraints with impunity.