In Bucklin v. United States (1895), the U.S Supreme Court ruled on a case involving an individual who was convicted for refusing to answer questions during a grand jury investigation into alleged customs fraud. The defendant, George E. Bucklin, argued that he could not be compelled to testify against himself under the Fifth Amendment of the Constitution and therefore his conviction should be overturned. However, the court disagreed with this argument stating that since he had not been charged with any crime at that point in time, his rights were not violated by being asked to provide testimony before a grand jury about potential criminal activity. Therefore, it upheld his conviction for contempt of court due to his refusal to answer questions from the grand jury.

In the dissenting opinion for Bucklin v. United States, it was argued that the majority's interpretation of federal jurisdiction over interstate commerce was too broad. The dissent contended that Congress only had authority to regulate trade between states and not within individual states themselves. They believed that by allowing federal regulation of intrastate commerce, as in this case where a man transported lottery tickets from Missouri to Kansas, the court was infringing upon state rights and powers reserved under the 10th Amendment. Furthermore, they asserted that if every act which might affect interstate commerce could be regulated by Congress then there would essentially be no limit to its power - an outcome they deemed contrary to constitutional principles of limited government and separation of powers.