In Ellis v. United States (1906), the U.S Supreme Court ruled on a case involving an individual named Charles G. Ellis who was convicted for embezzling funds from a national bank where he served as president. The main issue in this case was whether or not the court erred in instructing the jury that they could convict based solely on circumstantial evidence, without direct proof of guilt. The defense argued that there must be moral certainty and no room for reasonable doubt to convict based only on such evidence. The Supreme Court upheld Ellis's conviction, stating that it is within a jury's purview to decide if circumstantial evidence provides enough certainty of guilt beyond reasonable doubt. They further clarified that while direct testimony may often be more reliable than indirect or circumstantial evidence, it does not mean convictions cannot rest solely upon the latter when sufficiently compelling. This ruling reinforced legal precedent regarding evidentiary standards in criminal cases and affirmed juries' authority to weigh different types of evidence according their perceived reliability and credibility.

In the dissenting opinion for Ellis v. United States, Justice Harlan argued that the majority's decision to uphold Ellis' conviction was a dangerous expansion of federal power at the expense of state sovereignty. He contended that Congress had overstepped its constitutional bounds by criminalizing an act (in this case, peonage) which he believed fell under states' jurisdiction as part of their inherent police powers. Furthermore, he disagreed with the majority's interpretation of the Thirteenth Amendment and asserted it did not grant Congress unlimited authority to legislate against all forms of involuntary servitude but only those akin to African slavery. Thus, in his view, while peonage might be morally reprehensible and deserving punishment under state law; it should not be considered equivalent to slavery or subject to federal legislation under the Thirteenth Amendment.