In the 1893 case of Sarlls v. United States, the U.S Supreme Court examined whether a lower court had jurisdiction to try an American citizen for crimes committed in foreign waters on board a U.S.-flagged vessel. The defendant, Mr. Sarlls, was charged with manslaughter after killing another crew member while their ship was anchored off the coast of Japan. He argued that since the crime occurred outside U.S territory, he could not be tried under American law. The Supreme Court disagreed and upheld his conviction by affirming that federal courts have jurisdiction over criminal offenses committed by or against Americans on vessels flying the country's flag in international or foreign waters. This ruling established an important precedent regarding extraterritoriality and maritime law: it confirmed that national laws can apply to citizens abroad if they are aboard ships registered in their home country.

The dissenting opinion in the case of SARLLS v. UNITED STATES, 1893 argued that the majority's decision to uphold Sarlls' conviction for selling liquor without a license was incorrect. The dissenters believed that Sarlls had not violated any law because he sold alcohol on Native American land, which they viewed as outside federal jurisdiction. They contended that Congress did not have the power to regulate commerce within a state and therefore could not enforce its licensing laws on tribal lands. Furthermore, they disagreed with the majority's interpretation of treaties between Native American tribes and the U.S., arguing these agreements did not give Congress authority over internal affairs on reservations. In their view, upholding Sarlls' conviction infringed upon tribal sovereignty and exceeded Congressional powers under Constitution’s Commerce Clause.