In the 1942 case Direct Sales Co. v. United States, the U.S. Supreme Court ruled that a drug company could be held criminally liable for its role in an illegal narcotics distribution scheme, even if it did not directly participate in the illicit sales but merely had knowledge of them and facilitated their occurrence by supplying drugs to known dealers. The court found that Direct Sales Company was guilty of conspiracy to violate federal narcotic laws because they knowingly sold large quantities of morphine sulphate to a doctor who they knew intended to illegally distribute it without prescriptions or medical need justification. This ruling established important precedent regarding corporate liability and complicity in criminal activity.

In the dissenting opinion for DIRECT SALES CO. v. UNITED STATES, Justice Owen Roberts disagreed with the majority's interpretation of "in pursuance of a prescription" in relation to narcotics sales as outlined by federal law. He argued that Direct Sales Company had acted within legal boundaries when selling morphine sulphate to Dr. Schrader, who held a legitimate medical license and provided what appeared to be valid prescriptions for his patients' use - even if he later misused these drugs himself or sold them illegally. According to Justice Roberts, it was not reasonable or fair to hold Direct Sales Company criminally liable for Dr. Schrader's actions after they made their sale in good faith based on existing laws and regulations at that time.