In the 1892 case Earnshaw v. United States, the Supreme Court ruled on a matter involving fraudulent claims against the government. The defendant, Earnshaw, was charged with presenting false claims to several departments of the U.S government for payment and compensation for services not rendered or goods not delivered. He appealed his conviction arguing that he should have been tried separately for each claim rather than collectively in one trial. However, the Supreme Court upheld his conviction stating that all charges were part of a single continuous scheme to defraud different departments of government and therefore could be tried together as one offense under federal law at that time.

The dissenting opinion in Earnshaw v. United States argued that the majority's decision to uphold the conviction was incorrect because it failed to consider whether or not there was sufficient evidence for a jury to convict. The dissent pointed out that, while there may have been some circumstantial evidence pointing towards guilt, this did not necessarily mean that a reasonable jury would find beyond a reasonable doubt that Earnshaw had committed perjury. Furthermore, they disagreed with the majority's interpretation of what constituted "corrupt" behavior under the relevant statute and believed their overly broad definition could potentially criminalize innocent actions. They also took issue with how certain pieces of evidence were handled during trial and felt these errors further undermined confidence in the verdict.