In the 1914 case Henkel v. United States, the U.S Supreme Court ruled on a matter concerning extradition laws and procedures. The appellant, Max Henkel, was arrested in New York under an extradition treaty between Germany and the United States for embezzlement charges he faced in Germany. He challenged his arrest by filing a habeas corpus petition arguing that he had been charged with bankruptcy fraud rather than embezzlement which is not extraditable under the treaty terms. However, upon review of German law and its interpretation of "embezzlement," it became clear that what Germans considered as "embezzlement" included acts Americans would categorize as bankruptcy frauds or fraudulent conversion of property received in trust capacity (which were crimes committed by Henkel). Thus, despite differences in legal terminologies across countries involved in an extradition agreement - if there's substantial similarity between offenses' nature then they can be deemed equivalent for purposes of such treaties. Therefore, SCOTUS upheld lower court’s decision to deny Henkel's habeas corpus petition allowing his extradition to proceed.

In the dissenting opinion for Henkel v. United States, Justice Holmes disagreed with the majority's decision to uphold a contempt of court charge against an individual who refused to testify before a grand jury after being granted immunity from prosecution. He argued that the Fifth Amendment protection against self-incrimination should extend even when immunity is offered, as it was not within Congress' power to compel testimony by offering such protections. Furthermore, he contended that this interpretation violated fundamental principles of justice and liberty by forcing individuals into potentially incriminating situations without their consent or willingness. In essence, his argument centered on upholding constitutional rights over legislative attempts at circumvention.