In the case of Beavers v. Haubert in 1904, the U.S Supreme Court ruled that a person could not be tried twice for the same offense in different federal jurisdictions. The defendant, George E. Beavers Jr., was an employee of the Post Office Department who had been indicted on charges of conspiracy and bribery both in New York and Georgia based on his alleged acceptance of bribes to influence postal contracts. He argued that this constituted double jeopardy as he would essentially be tried twice for the same crime if prosecuted separately by each jurisdiction. The court agreed with Beavers' argument, ruling that while Congress has power to provide for punishing acts prohibited by law at any place within its jurisdiction, it does not have authority to punish such acts more than once when committed against a single sovereignty - even if they are punishable under different laws or occur within separate jurisdictions.

In the dissenting opinion for Beavers v. Haubert, Justice Harlan argued that the majority's interpretation of Article III, Section 2 of the Constitution was incorrect. He believed that this section did not prohibit a person from being tried twice for the same offense in different jurisdictions (federal and state). Instead, he interpreted it as only preventing double jeopardy within one jurisdiction. Thus, according to him, if a crime violated both federal and state laws simultaneously then separate prosecutions under each should be allowed without violating constitutional protections against double jeopardy. Furthermore, he contended that allowing such dual prosecutions would strengthen law enforcement by providing two avenues to punish wrongdoers who violate both federal and state laws concurrently.