In Cooke v. United States, 1924, the Supreme Court ruled on a case involving the right to trial by jury in contempt proceedings. The appellant was convicted of contempt for violating an injunction issued by a district court against striking railway workers and their union leaders during the Great Railroad Strike of 1922. He argued that he had been denied his constitutional right to be tried by a jury because his punishment exceeded petty offenses' usual limits (a fine exceeding $100 or imprisonment for more than six months). However, the Supreme Court upheld his conviction with Justice Sanford writing for majority opinion stating that there is no absolute right to trial by jury in cases of criminal contempt where penalties do not exceed those given for petty offenses.

In the dissenting opinion for Cooke v. United States, Justice McReynolds disagreed with the majority's decision to uphold a conviction based on an indictment that he believed was insufficiently specific. He argued that the indictment did not adequately detail how Cooke had violated federal law by conspiring to obstruct justice and interfere with witnesses in a pending case. According to McReynolds, this lack of specificity meant that Cooke could not properly prepare his defense or be protected from future prosecutions for the same offense. Furthermore, he contended that it was impossible for any court to know whether there was sufficient evidence supporting each element of such an undefined crime as charged in this case. Therefore, he concluded that upholding such a vague indictment would undermine fundamental principles of fairness and due process under U.S law.