In the case of Kinsella, Warden v. United States ex rel. Singleton (1959), the U.S Supreme Court ruled that a civilian dependent of a member of the armed forces could not be tried by court-martial for an offense committed overseas during peacetime. The petitioner, Mrs. Dorothy Krueger Smith Singleton was convicted in Japan by an American military tribunal for murdering her husband who was serving in the U.S Army at that time and sentenced to life imprisonment after being returned to America. She filed a habeas corpus petition challenging her conviction on constitutional grounds which were denied initially but later granted upon appeal before reaching Supreme Court review. The majority opinion held that Article 2(11) of Uniform Code Military Justice (UCMJ) -which extended court-martial jurisdiction over civilians accompanying armed forces abroad- violated Fifth Amendment rights providing due process and trial by jury as it applied to civilian dependents in peacetime situations outside US territories or possessions. This decision significantly limited military jurisdiction over civilians during times when no war has been declared, emphasizing civil courts' primacy unless explicitly authorized otherwise under Constitution.

In the dissenting opinion for Kinsella v. Singleton, Justice Frankfurter argued that military jurisdiction over civilian dependents of armed forces members stationed abroad should not be extended in peacetime. He believed this was a violation of Article III and the Fifth Amendment to the Constitution which guarantees civilians a trial by jury. The majority's decision, he contended, disregarded historical precedent limiting court-martial jurisdiction to service members or those directly associated with them during wartime only. Furthermore, he expressed concern about potential abuses of power if such broad authority were granted to military courts without explicit Congressional authorization or constitutional amendment.