In Steele v. United States, the Supreme Court of the United States was asked to decide whether a conviction for a federal crime could be based on circumstantial evidence. The case involved a man named Steele who was charged with the crime of counterfeiting. The government argued that Steele had been seen in the company of known counterfeiters and had been seen in possession of counterfeit money. Steele argued that this evidence was insufficient to convict him of the crime. The Supreme Court held that circumstantial evidence was sufficient to convict a person of a federal crime. The Court noted that circumstantial evidence was often more reliable than direct evidence, and that it was not necessary for the government to prove Steele's guilt beyond a reasonable doubt. The Court also noted that the jury was the ultimate arbiter of the facts and that it was up to the jury to decide whether the circumstantial evidence was sufficient to convict Steele. In conclusion, the Supreme Court held that circumstantial evidence was sufficient to convict a person of a federal crime. The Court noted that the jury was the ultimate arbiter of the facts and that it was up to the jury to decide whether the circumstantial evidence was sufficient to convict Steele.

Justice Harlan delivered the dissenting opinion in Steele v. United States, arguing that the majority had misconstrued the statute at issue and failed to consider its legislative history. He argued that Congress intended for section 5209 of the Revised Statutes to apply only when a person was charged with an offense against federal law, not when they were charged with violating state laws. The purpose of this provision was to protect individuals from being tried twice for a single crime by both federal and state governments; it did not provide immunity from prosecution under either government's laws. Justice Harlan further noted that if Congress had wanted to grant such immunity, it could have done so explicitly in other statutes or through amendments made since 1874 when section 5209 was enacted. Therefore, he concluded that there was no basis on which Steele should be granted immunity from his conviction under California law and dissented from the Court's ruling reversing his conviction