In the case of Clairmont v. United States (1911), the U.S Supreme Court upheld a conviction for perjury against Charles Clairmont, who had lied under oath during a bankruptcy proceeding. The main issue was whether or not his false testimony could be considered material to the proceedings and thus constitute perjury. The court ruled that it did, stating that any falsehood made under oath in an official proceeding is material if it has a tendency to influence or impede that proceeding, regardless of its actual effect on the outcome. This broad interpretation of "materiality" in relation to perjury set an important precedent for future cases involving false statements made under oath.

In the dissenting opinion for Clairmont v. United States, it was argued that the defendant's constitutional rights were violated due to an improper jury instruction. The justice believed that the trial court erred in instructing the jury that they could find guilt based on a presumption of intent from an act committed by the defendant. This, according to him, shifted burden of proof onto defendant and undermined his right to be presumed innocent until proven guilty beyond reasonable doubt. He contended this approach contradicted established legal principles which require direct evidence or inference from facts proved beyond reasonable doubt before a person can be found guilty of criminal intent. Thus, he disagreed with majority’s decision affirming conviction as he felt it compromised fundamental fairness guaranteed under constitution and set dangerous precedent for future cases.