In Bartell v. United States (1912), the U.S Supreme Court ruled that a defendant could be tried and convicted in any district where they were found, even if the crime was committed elsewhere. The case involved Charles Bartell, who had been arrested in New York for counterfeiting coins in Connecticut. He argued that his trial should have taken place in Connecticut since this is where he allegedly committed the crime. However, under federal law at the time, individuals accused of certain crimes could be tried either where they committed their offenses or wherever they happened to be apprehended by authorities. The court upheld this provision and rejected Bartell's argument on jurisdictional grounds.

In the dissenting opinion for Bartell v. United States, Justice Holmes argued that the defendant's actions did not constitute a crime under federal law. He contended that while Bartell may have been guilty of fraud or deceit, he was not guilty of counterfeiting as defined by statute because he had merely altered genuine banknotes rather than creating entirely false ones. The justice believed this distinction to be crucial and felt it should exempt Bartell from prosecution under counterfeiting laws. Furthermore, he suggested that if Congress intended to criminalize such behavior, they could amend the law accordingly but until then, it was inappropriate for courts to stretch existing statutes beyond their clear meaning in order to punish undesirable conduct.