In the case of Strassheim v. Daily (1910), the U.S. Supreme Court ruled on issues related to state jurisdiction and extradition between states. The defendant, Mr. Daily, was charged with conspiracy to defraud in Michigan but had fled to Illinois before he could be arrested or tried for his alleged crimes. When Michigan requested that Illinois extradite him back for trial, Daily argued that since he left Michigan before any charges were filed against him, he couldn't be considered a fugitive from justice under the federal Extradition Act. The Supreme Court disagreed with this argument and held that a person can still be considered a fugitive even if they leave a state before being formally charged with an offense there as long as their departure is motivated by an intent to avoid prosecution for their crime(s). Therefore, it upheld his extradition back to Michigan where he would face trial.

In the dissenting opinion for Strassheim v. Daily, Justice Harlan argued that a state cannot exercise its criminal jurisdiction over acts committed outside of its territory unless such acts are intended to produce and do produce detrimental effects within it. He disagreed with the majority's view that Michigan had jurisdiction simply because the fraudulent act was part of an ongoing scheme which began in Michigan. For him, this approach dangerously expanded states' power beyond their territorial limits without clear constitutional or legal basis. Furthermore, he emphasized that if every state could prosecute crimes based on where they were conceived rather than where they were executed, it would lead to chaos and potential abuses of power as multiple states could claim jurisdiction over a single crime.