In Bryant v. United States (1896), the Supreme Court ruled on a case involving an individual who had been convicted of murder in Indian Territory, which was under federal jurisdiction at the time. The defendant appealed his conviction to the Supreme Court, arguing that he should have been tried by a jury composed entirely of individuals from Indian Territory rather than by a mixed jury drawn from both Indian and Oklahoma Territories. He also claimed that certain evidence used against him during trial was improperly admitted because it violated his rights under the Fifth Amendment's protection against self-incrimination. However, after reviewing these arguments, the Supreme Court upheld his conviction unanimously. They found no error in how jurors were selected or how evidence was handled during trial; therefore they affirmed that due process had been followed throughout proceedings.

In the dissenting opinion for Bryant v. United States, Justice Harlan argued that the court majority erred in affirming the conviction of a man who was not present at his trial. He contended that this violated both common law principles and constitutional guarantees to due process. According to him, it is fundamental in all criminal trials that an accused has a right to be present from start until judgment; any deviation would mean denial of rights guaranteed by Constitution's Fifth Amendment - no person shall be deprived of life, liberty or property without due process of law. Furthermore, he pointed out inconsistencies with previous rulings where presence was deemed necessary even when defendant voluntarily absents himself after trial begins. Thus, he concluded that such absence does not waive one’s right to be present during entire proceedings and objected against allowing convictions under these circumstances.