Pettigrew v. United States was a Supreme Court case that addressed the issue of whether a defendant could be convicted of a crime if the evidence presented was circumstantial. The case involved a man named Pettigrew who was accused of stealing a horse. The prosecution presented evidence that Pettigrew had been seen in the vicinity of the horse shortly before it was stolen, and that he had been seen riding the horse shortly after it was stolen. The prosecution argued that this circumstantial evidence was sufficient to convict Pettigrew of the crime. The Supreme Court ultimately ruled in favor of Pettigrew, holding that circumstantial evidence alone was not sufficient to convict a defendant of a crime. The Court reasoned that circumstantial evidence was not as reliable as direct evidence, and that it was possible for a defendant to be convicted of a crime based on circumstantial evidence even if they were innocent. The Court also noted that circumstantial evidence could be easily manipulated or misinterpreted, and that it was not as reliable as direct evidence. As a result, the Court held that a defendant could not be convicted of a crime based solely on circumstantial evidence.

Justice Field delivered the dissenting opinion in Pettigrew v. United States, arguing that the majority's interpretation of the law was too broad and could lead to an unjust result. He argued that Congress had not intended for a person who committed a crime on Indian land to be subject to federal prosecution when they would otherwise only face state charges if it occurred elsewhere. Furthermore, he noted that this interpretation of the law would disproportionately affect Native Americans since many crimes occur on their reservations due to their unique circumstances and lack of resources available compared with other parts of society. Finally, Justice Field concluded by stating that such an expansive reading should not be applied without clear congressional intent or further guidance from higher courts as it could potentially lead to unfair results which were never intended by lawmakers.