In the 1930 case Various Items of Personal Property et al. v. United States, the U.S Supreme Court ruled that property used in violation of prohibition laws could be seized by the government even if its owner was not aware of and did not consent to its illegal use. The case involved a truck owned by a rental company that had been leased to an individual who used it for transporting alcohol, violating the Volstead Act which enforced Prohibition at that time. Despite arguments from the rental company claiming they were unaware of their vehicle's illicit use and thus should not have their property confiscated, Justice Pierce Butler writing for majority held that under federal law any vehicle involved in such violations could be forfeited regardless of whether or not its owner knew about or condoned those activities.

In the dissenting opinion for Various Items of Personal Property v. United States, the justice argued that the forfeiture of property used in violating prohibition laws was unconstitutional if it belonged to a person who had no knowledge or part in such violation. The justice contended that this interpretation violated both due process and unreasonable seizure protections under the Fourth and Fifth Amendments. They believed that an innocent owner should not be punished for crimes they did not commit nor had any awareness of, asserting that punishment without proven guilt is fundamentally unjust. Furthermore, they held concerns about potential abuses by law enforcement officials seizing property without proper justification or oversight.