In Hallowell v. United States (1907), the U.S Supreme Court upheld a lower court's decision that found Charles E. Hallowell guilty of embezzlement while serving as an assistant treasurer at the Sub-Treasury in San Francisco, California. The case centered on whether or not certain funds were considered public money and thus subject to laws against embezzlement by federal employees. The defense argued that because these funds had been deposited into a bank account rather than kept in the treasury vaults, they did not constitute "public money." However, the Supreme Court disagreed with this argument stating that once government revenues are received by authorized officials and placed into designated depositories for safekeeping until needed for disbursement according to law, such monies remain 'public' regardless of where they are stored or held.

The dissenting opinion in the case of Hallowell v. United States argued that the majority's decision was a misinterpretation of the law and an overreach of judicial power. The dissent contended that Congress, not the courts, should be responsible for determining whether or not certain actions constitute fraud under federal law. They also disagreed with the majority's interpretation of "intent to defraud," arguing it was too broad and could potentially criminalize innocent behavior. Furthermore, they believed that by upholding Hallowell’s conviction based on this broad definition, it would set a dangerous precedent where individuals could be convicted for acts they did not know were illegal at all. This view held firm to their belief in strict constructionism - interpreting laws as written without inferring broader meanings or implications - maintaining that any changes needed to address evolving societal norms or legal complexities should come from legislative action rather than judicial interpretation.