In the 1945 case of Howitt et al. v. United States, the Supreme Court ruled on a matter concerning conspiracy to defraud the U.S government by obstructing its functions and operations. The defendants were charged with conspiring to hinder and prevent enforcement of price regulations set forth under the Emergency Price Control Act during World War II through false statements and representations about their business transactions in wool products. They argued that they could not be convicted for conspiracy because they had already been acquitted in previous trials related to substantive offenses under this act. The court held that acquittal from specific charges does not protect one from being prosecuted for conspiracy if it is proven that there was an agreement or plan between two or more people aimed at committing illegal acts against government operations, even if those individual acts did not result in convictions themselves. Therefore, despite their prior acquittals on other charges relating to violations of wartime price controls, Howitt and his co-defendants were found guilty as charged due to sufficient evidence proving a criminal intent behind their actions which amounted to a broader scheme designed specifically with intentions of undermining federal law enforcement efforts.

In the dissenting opinion for Howitt et al. v. United States, the justice argued that the majority's decision to uphold convictions based on conspiracy charges was flawed due to insufficient evidence of a criminal agreement between defendants. The dissent emphasized that mere knowledge or approval of illegal activities does not constitute participation in a conspiracy unless there is clear proof of an agreement to violate law. Furthermore, it was pointed out that some defendants were convicted solely because they held positions within companies involved in illicit activities, without any direct evidence linking them personally to these crimes. This approach undermines fundamental principles of individual guilt and responsibility in criminal law and sets a dangerous precedent by potentially allowing for conviction based on association rather than proven involvement in crime.