In Parkinson v. United States, the Supreme Court was asked to decide whether a defendant could be convicted of a crime if the indictment failed to allege the essential elements of the offense. The defendant, Parkinson, had been convicted of a crime under a federal statute that prohibited the sale of liquor without a license. The indictment against Parkinson failed to allege that he had not obtained a license, which was an essential element of the offense. The Supreme Court held that the indictment was insufficient to support a conviction. The Court reasoned that the indictment must allege all of the essential elements of the offense in order to give the defendant notice of the charges against him. The Court noted that the indictment must be specific enough to enable the defendant to prepare a defense and to protect him from being tried twice for the same offense. The Court concluded that the indictment against Parkinson was insufficient and reversed his conviction.

Justice Field delivered the dissenting opinion in Parkinson v. United States, arguing that Congress did not have the power to pass a law which would allow for an appeal from a decision of the Court of Claims. He argued that such appeals were only allowed when specifically authorized by Congress and this was not one of those cases. Furthermore, he noted that allowing appeals from decisions made by the Court of Claims could lead to confusion and uncertainty as it would be difficult to determine what constituted an appealable case or issue. Finally, Justice Field concluded that if Congress wanted to provide for such appeals they should do so explicitly rather than relying on implied authority granted through other laws or statutes.