In Steele v. United States No. 2, the Supreme Court ruled that a federal court has jurisdiction to try a defendant for conspiracy even if the alleged crime was committed outside of its district. The case involved two defendants who were charged with conspiring in New York to commit mail fraud in Pennsylvania and Ohio. They argued that since they had not physically been present or taken any action within those states, the courts there did not have jurisdiction over them. However, Justice Holmes writing for the majority held that because their actions intended to produce unlawful effects within those districts, it was sufficient grounds for prosecution there under federal law.

In the dissenting opinion for Steele v. United States No. 2, Justice McReynolds argued that the majority's decision to uphold a conviction based on evidence obtained through wiretapping was fundamentally flawed and violated constitutional rights. He contended that this ruling would set a dangerous precedent by allowing law enforcement agencies to use invasive surveillance methods without any checks or balances in place, thereby undermining individual privacy rights protected under the Fourth Amendment of the Constitution. Furthermore, he believed that such practices were not only unconstitutional but also unethical and contrary to principles of justice and fairness upon which American legal system is founded. Therefore, he strongly disagreed with his colleagues' interpretation of existing laws related to search warrants and seizures as well as their failure to recognize potential abuses associated with unrestricted wiretapping activities.