In Smith v. United States (1897), the U.S Supreme Court ruled that a person who voluntarily becomes intoxicated cannot use their drunkenness as an excuse for committing a crime, specifically in this case, murder. The defendant argued that he was so drunk at the time of the killing that he could not have formed malice aforethought - a necessary element to be convicted of murder. However, it was held by Justice Harlan and his colleagues on behalf of unanimous court that voluntary intoxication is not a defense against criminal charges because it does not negate intent or premeditation required for such crimes. This decision established precedent regarding how courts should handle cases where defendants claim they were too intoxicated to form intent to commit crime.

In the dissenting opinion for Smith v. United States, Justice Harlan argued that the majority's decision was a misinterpretation of the law and an overreach of federal power. He contended that Congress did not have authority to regulate commerce within individual states, only between them. Therefore, he believed it was inappropriate for federal courts to prosecute crimes committed on land owned by individuals or corporations within state borders, even if those lands were used in interstate commerce activities such as railroads. In his view, this interpretation would lead to an unwarranted expansion of federal jurisdiction into areas traditionally controlled by state governments - a violation of principles underlying American Federalism.