In the case of Calvin Smith v. United States in 2012, the Supreme Court ruled on a matter related to drug trafficking and conspiracy charges. Smith was convicted for his involvement in a large-scale drug operation, but he argued that there wasn't sufficient evidence to prove he had joined or participated in the conspiracy. The court disagreed with him and upheld his conviction based on two main pieces of evidence: firstly, recorded phone conversations where Smith discussed details about drug transactions; secondly, physical evidence including drugs found at his residence during a search by law enforcement officers. This case is significant as it clarified that participation in individual illegal acts can be enough to demonstrate involvement in larger criminal conspiracies under federal law.

In the dissenting opinion for Calvin Smith v. United States, Justice Scalia argued that the majority's interpretation of "in relation to" in 18 U.S.C §924(c) was too broad and inconsistent with previous interpretations of similar phrases in other statutes. He contended that this expansive interpretation could lead to absurd results where a person could be charged with a crime even if their possession of a firearm had nothing to do with another offense they committed. For example, he suggested that under the majority's reading, someone who carried a gun while jaywalking could potentially be charged under §924(c). Furthermore, he criticized the majority for failing to apply traditional canons of statutory construction such as noscitur a sociis (a word is known by its associates), which would have limited "in relation to" based on surrounding words like “uses” or “carries”. In his view, these terms suggest an active employment or direct involvement of firearms in criminal activity rather than mere possession.