In the case of Johnson Alias Overton v. United States (1894), the U.S Supreme Court upheld a lower court's decision to convict Mr. Johnson, also known as Overton, for murder on an American ship in international waters off the coast of Brazil. The defense argued that since the crime occurred outside U.S territory, it was beyond its jurisdiction and should be dismissed. However, citing previous cases and maritime law principles, Justice Gray wrote for a unanimous court stating that crimes committed by or against Americans on American vessels in international waters are within U.S jurisdiction regardless of their location at sea.

In the dissenting opinion for Johnson Alias Overton v. United States, Justice Brewer argued that the defendant's constitutional rights were violated due to a lack of proper counsel during his trial. He believed that this was not just an error but a fundamental flaw in the proceedings which rendered them null and void. The accused had been denied his Sixth Amendment right to legal representation, as he was only provided with an attorney on the day of his trial without any prior consultation or preparation time. This did not allow him adequate opportunity to prepare a defense or understand the charges against him fully. Therefore, according to Justice Brewer, it constituted grounds for overturning his conviction and ordering a new trial where these rights would be respected.