In Potter 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 an essential element of the offense. The defendant, Potter, had been convicted of a crime under the Internal Revenue Act of 1867, which required the defendant to have acted “willfully” in order to be found guilty. The indictment against Potter failed to allege that he acted willfully, and Potter argued that this omission was fatal to the indictment. The Supreme Court held that the omission of the word “willfully” from the indictment was not fatal to the indictment. The Court reasoned that the indictment was sufficient to put Potter on notice of the charge against him, and that the jury was instructed on the element of willfulness. The Court also noted that the indictment was not required to use the exact language of the statute, and that the omission of the word “willfully” did not render the indictment defective. The Court’s decision in Potter v. United States established that an indictment is sufficient if it puts the defendant on notice of the charge against him, even if it does not use the exact language of the statute. The Court also held that the omission of an essential element of the offense from the indictment does not render the indictment defective, as long as the jury is instructed on the element.

Justice Field delivered the dissenting opinion in Potter v. United States, arguing that Congress did not have the power to pass a law which would allow for an individual to be convicted of a crime without proof of criminal intent. He argued that this was contrary to long-established principles of criminal law and violated due process rights guaranteed by the Fifth Amendment. Justice Field further noted that if such laws were allowed, then individuals could be held liable for acts they had no knowledge or intention of committing, thus creating an unjust system where people are punished without any fault on their part. In conclusion, he argued that Congress should not be able to pass laws which violate fundamental constitutional protections and urged his colleagues on the Court to reject this interpretation as it would lead down a dangerous path towards tyranny and injustice.