In the Logan v. United States case of 1891, the U.S Supreme Court ruled that a defendant cannot be convicted for assault with intent to commit murder if there is no evidence proving that he had specific intent to kill. The case involved John A. Logan who was charged and convicted in Utah Territory's district court for assaulting another man with an intention to commit murder. However, on appeal, the Supreme Court reversed this decision stating that while it was clear from evidence presented at trial that Logan had assaulted his victim, there wasn't sufficient proof showing he intended to take his life during the attack. Therefore, according to Justice Samuel Blatchford who delivered the opinion of the court, without such proof of specific intent to kill being shown beyond reasonable doubt by prosecution as required under law defining crime charged (Section 5352), conviction could not stand.

In the dissenting opinion for Logan v. United States, Justice Lamar argued that the majority's interpretation of the Enforcement Act was too broad and exceeded its intended scope. He contended that Congress had only meant to protect citizens from violations of their civil rights by state actors, not private individuals. Therefore, he believed that a private individual could not be prosecuted under this act for conspiring to deprive another person of his or her constitutional rights unless it involved state action. Furthermore, he expressed concern about federal overreach and warned against expanding federal jurisdiction into areas traditionally reserved for states' law enforcement powers such as criminal conspiracy cases involving purely local matters.