In the case of In re Quarles and Butler, 1894, the U.S. Supreme Court was asked to decide whether a federal law that made it a crime to obstruct or resist any officer of the United States in serving or executing any legal or judicial writ could be applied when an individual resisted arrest by a private person who had been deputized by a U.S. marshal. The petitioners argued that they were not guilty because they did not know at the time of their resistance that they were resisting an officer performing his duties under federal authority. The court ruled against them, stating that ignorance of this fact did not excuse their actions as long as it could be proven beyond reasonable doubt that at the time of resistance, there existed intent to oppose execution of process by whomever might attempt its service. Therefore, even though Quarles and Butler may have thought they were resisting arrest from private individuals rather than officers acting on behalf of federal authorities, their lack of knowledge didn't absolve them from guilt under this particular statute.

The dissenting opinion in the case of In re Quarles and Butler, 1894, argued that the majority's interpretation of Congress' power under the Constitution was too broad. The dissenters believed that Congress did not have unlimited authority to legislate on all matters related to crime and punishment. They contended that such an expansive view could potentially infringe upon states' rights and individual liberties protected by the Constitution. Furthermore, they disagreed with the majority's assertion that a person who aids or abets a criminal act is as guilty as if he had committed it himself. The dissenters felt this principle should only apply when there is clear evidence showing intent to aid in committing a crime rather than merely being present at its commission.