In the 1920 case of Horning v. District of Columbia, the U.S. Supreme Court upheld a conviction for selling goods at higher than legally permitted prices during World War I under D.C.'s wartime price control laws. The defendant, Joseph Horning, argued that his constitutional rights were violated because he was not provided with a jury trial and that the fines imposed on him were excessive in violation of Eighth Amendment protections against cruel and unusual punishment. However, the court ruled unanimously that these claims lacked merit as there is no constitutional right to a jury trial for petty offenses and it did not consider $300 fine per offense to be excessive or disproportionate given the circumstances.

In the dissenting opinion for Horning v. District of Columbia, Justice Holmes argued that the case should not have been dismissed on grounds of insufficient evidence. He believed that there was enough circumstantial evidence to suggest guilt and therefore a trial was warranted. Furthermore, he disagreed with the majority's interpretation of reasonable doubt, arguing that it is not necessary for every piece of evidence to point towards guilt in order for a conviction to be valid; rather, all pieces considered together must create an overwhelming likelihood of guilt. Finally, he expressed concern over how this decision might set a precedent which could potentially undermine future prosecutions based on circumstantial evidence alone.