In the 1923 case of Dorchy v. State of Kansas, the U.S. Supreme Court overturned a conviction for violating prohibition laws on procedural grounds. The defendant, Dorchy, was convicted in Kansas state court for possessing alcohol with intent to sell during Prohibition. However, his indictment did not specify when or where he allegedly committed this crime - details that are typically required under due process rights established by the Fourteenth Amendment to ensure fair trials and allow defendants adequate opportunity to prepare their defense. The Supreme Court ruled unanimously that these omissions rendered Dorchy's indictment invalid and reversed his conviction.

In the dissenting opinion for Dorchy v. State of Kansas, Justice Oliver Wendell Holmes Jr. argued that the state law in question, which limited miners' workdays to eight hours unless they voluntarily chose to work longer, was not unconstitutional as it did not infringe upon workers' liberty or freedom of contract under the Fourteenth Amendment. He believed that such a regulation fell within a state's police power and served its interest in protecting public health and safety by preventing overwork and exhaustion among miners. Furthermore, he contended that if an employee willingly agreed to work beyond these limits without coercion from their employer or fear of losing their job, then this should be considered voluntary rather than forced labor. Therefore, he disagreed with the majority's ruling striking down this law on constitutional grounds.