In the case of Williams v. United States in 1950, the Supreme Court ruled on whether a defendant could be convicted for bank robbery under Section 2113(d) of Title 18 if they had not physically harmed anyone during the crime. The defendant, Williams, argued that he should have been charged under Section 2113(a), which carries a lesser penalty because no one was assaulted or put in jeopardy during his crime. However, the court disagreed and upheld his conviction under section (d). They reasoned that even though no physical harm occurred, by carrying a gun and threatening to use it if necessary constituted an "assault" as defined by law - putting someone's life in danger with violence from a deadly weapon. Therefore, this act fell within the purview of section (d), justifying its application and corresponding harsher penalties.

In the dissenting opinion for Williams v. United States, Justice Frankfurter argued that the majority's decision to uphold a conviction based on evidence obtained through an illegal search and seizure was contrary to constitutional principles. He contended that such evidence should be excluded from trial as it violated Fourth Amendment protections against unreasonable searches and seizures. Furthermore, he believed this ruling would encourage law enforcement officers to disregard citizens' constitutional rights in their pursuit of criminal convictions. The justice also expressed concern about the potential erosion of civil liberties if courts continued to allow illegally obtained evidence into trials, arguing that these practices threatened fundamental democratic values by undermining public trust in legal institutions.