In the case of Ezekiel Simpson v. The United States, the Supreme Court was asked to decide whether a person convicted in a state court for an offense that is also punishable by federal law can be tried again in federal court for the same crime. In this particular case, Simpson had been convicted and sentenced to death by a Virginia state court for murder but then he was indicted on similar charges in U.S. Circuit Court under federal laws prohibiting murder within Indian country or any other place subject to exclusive jurisdiction of Congress. The Supreme Court held that double jeopardy did not apply because it only applies when two sovereigns are involved and since both trials were conducted under authority of one sovereign (the United States), there could be no double jeopardy violation as defined by the Fifth Amendment's Double Jeopardy Clause which prohibits successive prosecutions from different sovereignties based on same criminal act or transaction.

In the case of Ezekiel Simpson v. The United States, the Supreme Court was asked to determine whether a slave owner had forfeited his right to reclaim an escaped slave by failing to pursue him in a timely manner. Justice McLean wrote a dissenting opinion arguing that Congress did not intend for slaves who had been absent from their owners for more than one year and one day to be considered as having been abandoned or lost forever. He argued that this interpretation would lead to unjust results because it could encourage unscrupulous individuals who were aware of the time limit on pursuing runaway slaves, such as bounty hunters, kidnappers, and other criminals looking for easy money. Furthermore, he noted that if Congress intended such an outcome they would have explicitly stated so in legislation rather than leaving it up to judicial interpretation. Therefore he concluded that since there was no clear intent from Congress regarding how long someone should wait before declaring their property lost or abandoned then any reasonable amount of time should be allowed when determining ownership rights over escaped slaves