In the 1920 case of State of Minnesota on the Relation of Whipple v. Martinson, Sheriff of Hennepin County, Minnesota, the U.S. Supreme Court ruled in favor of Martinson. The case revolved around a dispute over whether or not an individual could be extradited from one state to another for prosecution under a criminal statute that was enacted after he had left the first state. The court held that extradition is permissible even if it involves returning someone to face charges under laws passed after they departed from that jurisdiction. This decision established important legal precedent regarding interstate extradition and has been cited in numerous subsequent cases involving similar issues.

In the dissenting opinion for Whipple v. Martinson, it was argued that the state of Minnesota had not violated Whipple's constitutional rights by refusing to release him from jail on a writ of habeas corpus. The justice contended that while the U.S Constitution does protect against unlawful imprisonment, it does not guarantee an absolute right to bail in all cases. He further asserted that states have broad discretion in determining whether or not to grant bail and under what conditions, as long as they do so within reasonable bounds and without discrimination or prejudice. In this case, he believed Minnesota acted within its authority when denying bail due to concerns about public safety given Whipple's criminal history and potential flight risk.