In the case of Bothwell et al. v. United States in 1920, the Supreme Court was asked to determine whether a federal law that imposed taxes on inheritances from deceased non-resident aliens was constitutional. The plaintiffs, heirs to an estate left by a Canadian citizen who owned property in Washington state at his time of death, argued that this tax violated their rights under both U.S and international law as it discriminated against foreign citizens' estates compared to domestic ones. However, the court ruled unanimously against them stating that Congress has broad powers when it comes to taxation and can impose different rates for residents and non-residents if they see fit without violating any constitutional principles or treaties with other nations.

In the dissenting opinion for BOTHWELL et al. v. UNITED STATES, 1920, it was argued that the majority's decision to uphold a conviction based on an indictment which did not specify any particular act of fraud was erroneous and violated fundamental principles of justice. The dissent contended that in order to be valid under the Constitution, an indictment must provide sufficient detail about the alleged offense so as to enable a defendant to prepare their defense and avoid being subjected twice for the same offense (double jeopardy). In this case, however, no specific fraudulent acts were identified in relation with defendants' conspiracy charge; thus making it impossible for them to adequately defend themselves or prevent future prosecutions for similar offenses. Furthermore, they believed that such vague indictments could potentially lead prosecutors into abusing their power by bringing charges without clear evidence of wrongdoing.