In the case of District of Columbia v. Clawans, the U.S. Supreme Court ruled in 1936 that a criminal defendant cannot be convicted based solely on circumstantial evidence if direct evidence is available but not presented by the prosecution. The case involved Samuel Clawans who was charged with receiving stolen goods - specifically, two tires and tubes from an unknown person or persons. The only evidence against him was his possession of these items which were identified as part of those stolen from a tire company's warehouse earlier. However, there were no witnesses to testify directly about how he came into possession of them nor any other direct proof linking him to their theft or receipt knowing they had been stolen. The court held that when such direct testimony is absent and could have been provided by the prosecution but wasn't, it would be unjust to allow conviction merely based on inference drawn from mere possession alone without further corroborative circumstances indicating guilt beyond reasonable doubt.

In the dissenting opinion for District of Columbia v. Clawans, Justice Cardozo disagreed with the majority's decision to overturn a conviction based on insufficient evidence. He argued that it was not within the Supreme Court's jurisdiction to review facts and evidence in criminal cases unless there was an exceptional circumstance or constitutional issue at stake. In this case, he believed that no such issues were present and therefore, the court should have deferred to lower courts' judgment about whether enough evidence existed for a conviction. Furthermore, he contended that even if reviewing factual sufficiency was within their purview, sufficient circumstantial evidence did exist in this case to uphold Clawans' conviction for selling used mattresses without proper sanitation procedures as required by law.