In Relford v. Commandant, U.S. Disciplinary Barracks, Ft. Leavenworth (1970), the Supreme Court examined whether a military court had jurisdiction over crimes committed by an active duty serviceman against civilians on a military base but outside of federal exclusive legislative jurisdiction areas. The petitioner, Curtis Lee Relford was convicted in a general court-martial for various offenses against eight women near Fort Hood, Texas where he was stationed as an Army private first class at the time of his offenses. Relford argued that under Article 2(11) of the Uniform Code of Military Justice (UCMJ), which limits courts-martial jurisdiction to "offenses that are triable by such courts or tribunals and have been recognized as service connected," his crimes were not sufficiently service-connected to be tried in a military court because they occurred off-base and involved civilian victims. The Supreme Court disagreed with this argument and upheld Relford's conviction stating that there is no requirement for both offender and victim to be within federal exclusive legislative jurisdictions for military law application; it suffices if either one is present therein when crime occurs.

In the dissenting opinion for Relford v. Commandant, U.S. Disciplinary Barracks, Ft. Leavenworth (1970), Justice Hugo Black argued that the military court did not have jurisdiction over crimes committed by servicemen off base and against civilians. He contended that such cases should be tried in civilian courts to ensure constitutional protections are upheld for all citizens, including those serving in the military. In his view, allowing a military tribunal to try these types of cases could lead to abuses of power and potential violations of individual rights as guaranteed under the Constitution's Bill of Rights - particularly with regards to fair trial standards and protection from self-incrimination.