In the Shields v. United States case of 1926, the Supreme Court ruled on a matter involving federal jurisdiction over crimes committed in U.S. territories. The defendant, Shields, was convicted for murder in Alaska and appealed his conviction to the Ninth Circuit court arguing that he should have been tried by an Alaskan territorial court instead of a federal one as Alaska wasn't officially recognized as a state at that time. However, the Supreme Court upheld his conviction stating that even though Alaska was not yet formally admitted into Union as a state during this period, it still fell under U.S.'s national sovereignty and thus its laws were applicable there including those governing serious crimes like murder which fall under federal jurisdiction.

In the dissenting opinion for Shields v. United States, the justice argued that there was a lack of evidence to support the conviction of conspiracy against Shields and his co-defendants. The dissent focused on two main points: first, that mere association with known criminals or presence at meetings where illegal activities are discussed does not constitute participation in a criminal conspiracy; secondly, it is necessary to prove beyond reasonable doubt that an individual had knowledge of and intended to participate in the unlawful plan. In this case, according to the dissenter's view, no such proof was provided by prosecution. Therefore, he believed that convicting Shields based solely on circumstantial evidence violated his rights under due process clause of Fifth Amendment which requires fair procedures before depriving someone’s liberty.