John C. Almy, Jun., brought a case before the United States Supreme Court challenging his conviction in California for selling liquor without a license. He argued that he had been denied due process of law because the trial court had refused to allow him to introduce evidence on his behalf and failed to provide an interpreter when requested. The Supreme Court found that while it was true that Almy's rights were violated by not being allowed to present evidence or having access to an interpreter, this did not constitute sufficient grounds for overturning the conviction as there was still enough other evidence presented at trial which could have led the jury to convict him regardless of these errors. Ultimately, they ruled against Almy and upheld his conviction.

Justice Field delivered the dissenting opinion in this case, arguing that the California Supreme Court erred in its decision. He argued that a state cannot constitutionally pass a law which would allow for an individual to be convicted of murder without proof of malice aforethought. In other words, he believed it was unconstitutional for the state to convict someone based on circumstantial evidence alone and not require any proof of intent or malice. Justice Field further argued that if such laws were allowed, then individuals could be convicted even when they had no intention whatsoever to commit murder; thus violating their constitutional right against cruel and unusual punishment as well as due process rights under the Fourteenth Amendment. Ultimately, Justice Field concluded by stating that allowing states to pass such laws would lead to arbitrary convictions with little regard for justice or fairness - something which should never happen in America's criminal justice system.