In the 1909 case of Haas v. Henkel, the United States Supreme Court dealt with issues surrounding extradition and jurisdiction. The petitioner, Julius Wadsworth Haas, was indicted in New York for conspiracy to defraud the U.S government but was arrested in Georgia where he resided. He contested his removal to New York arguing that since he had not fled from New York to avoid prosecution, he should be tried in Georgia instead. However, the court ruled against him stating that under federal law a person charged with a crime can be arrested and tried wherever they are found within U.S territory regardless of whether or not they have fled from another state to evade justice. This ruling established an important precedent regarding interstate rendition which is still followed today.

The dissenting opinion in the case of Haas v. Henkel, 1909, was written by Justice Harlan. He disagreed with the majority's interpretation of the constitutional provision regarding extradition between states. According to him, this provision should not be applied to cases involving federal crimes as it was designed for state-level offenses only. He argued that applying this rule at a federal level would give too much power to individual U.S Marshals and could potentially lead to abuses such as unlawful arrests or detentions without proper legal procedures being followed. Furthermore, he believed that if an individual is accused of committing a crime in one district but found in another district within the same state, they should be tried where they were found rather than being forcibly taken back to where the alleged offense occurred.