In the case of Brown v. United States in 1893, the Supreme Court ruled on a matter involving maritime law and salvage rights. The plaintiff, Brown, had salvaged a sunken vessel owned by the U.S government during peacetime without explicit permission from any governmental authority. He then sought compensation for his efforts under international salvage laws which allow individuals who voluntarily save another's property at sea to claim remuneration. However, the court held that these laws did not apply as it was domestic waters and during peacetime; therefore, federal law governed this situation instead of international maritime law. The court stated that while there is no specific statute prohibiting such actions or requiring prior authorization before undertaking them in U.S waters during peace times, unauthorized persons cannot interfere with government property even if their intentions are good unless they can prove an immediate necessity to act due to impending danger or destruction of said property. Therefore, despite acknowledging Brown's effort and expense in raising the shipwrecked vessel (which indeed benefited the Government), he was denied any reward because he acted without official sanction or demonstrated necessity.

In the dissenting opinion for Brown v. United States, Justice Brewer argued that the majority's decision to uphold a conviction based on circumstantial evidence was flawed. He contended that while such evidence could be used in some cases, it should not have been sufficient in this particular case due to its weak nature and lack of corroboration. Furthermore, he expressed concern about potential miscarriages of justice if convictions were allowed based solely on circumstantial evidence without any direct proof or eyewitness testimony supporting it. He believed that the court had set a dangerous precedent by allowing such weak and uncorroborated circumstantial evidence to serve as the basis for a criminal conviction.