In Simpson v. United States (1898), the Supreme Court ruled on a case involving an individual who was charged with selling liquor without paying the special tax required by law. The defendant, Simpson, argued that he had not sold any liquor but only exchanged it for goods and services at his store in Indian Territory. He contended that this did not constitute "selling" as defined by the statute under which he was prosecuted. However, the court disagreed with him and upheld his conviction. The key issue before the Supreme Court was whether exchanging liquor for goods or services constituted a sale within meaning of federal laws imposing taxes on those who sell spirits without having paid special tax therefor. The court held that such exchanges indeed amounted to sales because they involved transfer of ownership from one party to another in return for something else of value. Therefore, even though no money changed hands directly between Simpson and his customers when they received alcohol from him, these transactions were still considered sales because they resulted in change of possession accompanied by receipt of some form of compensation.

In the dissenting opinion for Simpson v. United States, 1898, it was argued that the majority's interpretation of the law in question was incorrect and overly broad. The dissenting justices believed that Congress did not intend to include all types of property within its definition when drafting legislation related to theft from interstate commerce. They contended that a more narrow interpretation should be applied, limiting its scope only to goods or wares intended for transportation across state lines as part of commercial trade activities. Furthermore, they disagreed with the majority's assertion that any ambiguity in statutory language should be resolved in favor of broader federal jurisdiction over criminal matters; instead arguing such ambiguities ought to be interpreted narrowly so as not to infringe upon states' rights and individual liberties unnecessarily.