In Rainey v. United States (1913), the Supreme Court ruled on a case involving Joseph H. Rainey, who was charged with conspiracy to defraud the government by using fraudulent means to secure land patents from the Department of Interior for his clients. The main issue in this case was whether or not an indictment that charges two separate and distinct offenses can be sustained under one count. The court held that it could not; each offense should have been stated in a separate count because they were different both in law and fact, even though they related to the same transaction. Rainey argued that he had been improperly indicted because his actions constituted two distinct crimes: fraudulently securing patents and conspiring to commit fraud against the U.S Government - which should have been charged separately according to him. The Supreme Court agreed with Rainey's argument, stating that "the well-settled rule is that when an indictment contains but one count charging but one crime, evidence cannot be admitted of another crime." Therefore, it reversed his conviction due its failure to distinguish between these two criminal acts.

In the dissenting opinion for Rainey v. United States, it was argued that the defendant's conviction should be overturned due to a lack of evidence proving his guilt beyond reasonable doubt. The dissenting justices believed that there were significant issues with how the trial was conducted, including questionable jury instructions and improper admission of evidence. They also took issue with how certain testimonies were handled during the trial proceedings. Furthermore, they disagreed with majority’s interpretation of relevant laws and felt that these interpretations unfairly prejudiced against Rainey in this case. Therefore, they concluded that justice had not been served by upholding Rainey's conviction.