In Griffin v. United States (1948), the Supreme Court ruled that a jury's verdict can be upheld even if one of the possible grounds for conviction was unsupported by sufficient evidence, as long as at least one valid ground is supported by adequate proof. The case involved two defendants who were convicted of mail fraud based on three separate schemes. On appeal, they argued that there wasn't enough evidence to support all three schemes and therefore their convictions should be overturned. However, the Supreme Court disagreed stating that it was impossible to know which scheme(s) led to their conviction and thus affirmed their sentences because at least one scheme had substantial supporting evidence.

In the dissenting opinion for Griffin v. United States, Justice Jackson disagreed with the majority's decision to uphold Griffin's conviction. He argued that there was insufficient evidence to prove beyond a reasonable doubt that Griffin had knowingly participated in a conspiracy to defraud the U.S government. According to Justice Jackson, mere association with conspirators or knowledge of illegal activities is not enough; active participation must be proven. Furthermore, he criticized the Court’s reliance on Pinkerton v. United States (1946), which held co-conspirators liable for each other’s actions even if they were unaware of them at the time they occurred - an approach he considered unjust and contrary to traditional principles of criminal law and personal guilt.