In the 1912 case Ex Parte United States, the U.S. Supreme Court ruled that a federal judge did not have the authority to suspend or reduce a criminal sentence once it had been imposed and entered into court records unless new evidence was presented. The case arose after Judge Emory Speer of Georgia reduced sentences he had given to two men convicted of illegal liquor trafficking, citing their good behavior in prison as his reason for doing so. The government challenged this decision, arguing that once a sentence is officially recorded by the court clerk, it becomes final and can only be changed if there are legal errors or new facts come to light. In its ruling, written by Justice Joseph Rucker Lamar, the Supreme Court agreed with this argument and held that judges do not have inherent power to modify sentences based on factors such as prisoner conduct.

In the dissenting opinion for Ex Parte United States, 1912, it was argued that the majority's decision to allow a federal court to impose criminal contempt sanctions without a jury trial conflicted with constitutional principles. The dissenters believed that this ruling violated an individual's Sixth Amendment right to a jury trial in all criminal prosecutions. They contended that if someone could be punished by imprisonment for more than six months without being afforded their constitutionally guaranteed rights, then there would be no limit on what punishments could be imposed upon them without these protections. Furthermore, they expressed concern about potential abuses of power and arbitrariness from judges who might use such broad authority vindictively or capriciously.