In the case of Leighton et al. v. United States in 1932, the Supreme Court examined whether a federal court had jurisdiction over an alleged violation of U.S. customs laws that occurred on a British ship located within three miles off the coast of California but outside state territorial waters. The defendants were charged with smuggling alcohol into the country during Prohibition and argued that they could not be prosecuted under U.S law because their actions took place on foreign soil (the British ship). However, the Supreme Court ruled against them, stating that while ships are generally considered part of their home nation's territory for many purposes, this principle does not apply when it comes to enforcing revenue or prohibitory regulations like those involved in this case. Therefore, even though they were aboard a British vessel at time of arrest, they were still subject to American law enforcement jurisdiction as long as they intended to smuggle goods into U.S territory.

In the dissenting opinion for Leighton et al. v. United States, Justice McReynolds argued that the majority's decision to uphold the defendants' convictions was incorrect because it failed to consider whether or not there had been an abuse of discretion by the trial court in admitting certain evidence. He believed that this failure violated a fundamental principle of justice and fairness, as it allowed potentially prejudicial evidence to be presented without proper scrutiny. Furthermore, he contended that even if such an abuse did not occur in this particular case, upholding these convictions would set a dangerous precedent for future cases where similar issues might arise. Therefore, he dissented from the majority's ruling and advocated for a reversal of the defendants' convictions.