In the case of Deal et al. v. United States, 1926, the Supreme Court was asked to determine whether a federal law that imposed penalties for theft from interstate shipments applied when goods were stolen after they had reached their final destination but before they had been delivered to the consignee. The defendants in this case were convicted under this law for stealing whiskey from a railroad car in Tennessee after it had arrived at its final stop but before delivery to the consignee. They appealed on grounds that since shipment ended upon arrival at its destination and not until actual delivery, therefore federal jurisdiction ceased as well. The Supreme Court upheld their convictions stating that although technically speaking transportation ends when goods reach their intended location; however, practical considerations necessitate extending protection until actual delivery is made because otherwise thieves could simply wait until items have reached their destinations and then steal them without fear of federal prosecution.

The dissenting opinion in the case of DEAL et al. v. UNITED STATES argued that the majority's interpretation of "use" in 18 U.S.C §924(c)(1) was too broad and not consistent with Congress' intent when it enacted the statute. The dissent believed that a defendant should only be subject to multiple punishments under this law if they commit separate, distinct acts of firearm use or possession during different crime occurrences, rather than being penalized for each subsequent conviction stemming from a single criminal episode involving one gun. They contended that such an expansive reading could lead to disproportionately severe sentences and potentially violate constitutional protections against double jeopardy.