In the case of Grunewald v. United States, 1956, the Supreme Court ruled in favor of defendants who had been convicted for conspiracy to defraud the U.S. government by preventing it from collecting income taxes rightfully owed by certain taxpayers. The court held that there was insufficient evidence to prove a continuous conspiracy extending beyond an initial scheme to obtain "no prosecution" rulings from tax authorities and into a period when alleged acts of concealment occurred. The majority opinion emphasized that mere efforts at concealment following commission of a crime do not extend its duration or constitute part of an ongoing criminal plot unless specifically included as part of the original plan agreed upon by conspirators. Therefore, since no such agreement was proven in this case, convictions based on acts occurring outside statute-of-limitations were reversed.

In the dissenting opinion for Grunewald v. United States, Justice Clark argued that the majority had misinterpreted both the facts and law of this case. He contended that there was sufficient evidence to support a conspiracy charge against the defendants, who were accused of attempting to defraud the government by obtaining fraudulent tax refunds. According to him, it was not necessary for every conspirator to know all details or participate in every act; their common goal was enough proof of conspiracy. Furthermore, he disagreed with how statutes of limitations should apply in such cases - arguing that they should start from when an overt act is committed during ongoing concealment efforts rather than at initial crime's completion as held by majority view. The justice also criticized his colleagues' decision on evidentiary matters and believed they overstepped their role as appellate judges by reevaluating witness credibility and weighing evidence – tasks typically reserved for trial courts.