In the 1916 case Sutton v. State of New Jersey, the U.S Supreme Court upheld a decision by the New Jersey courts to convict William Sutton for murder. The defense argued that there were errors in his trial, including allegations of jury misconduct and improper instructions given to jurors about reasonable doubt. However, after reviewing these claims, the Supreme Court found no substantial error that would warrant overturning Sutton's conviction. They held that while it is important for juries to be properly instructed on reasonable doubt standards, minor deviations from ideal language do not necessarily invalidate a verdict if they do not mislead or confuse jurors about their duty under law. Furthermore, they ruled that alleged juror misconduct must be proven with clear evidence before it can affect a verdict - mere suspicion or conjecture is insufficient.

In the dissenting opinion for Sutton v. State of New Jersey, Justice Holmes argued that the defendant's conviction was based on a misinterpretation of the law and should be overturned. He contended that while it is illegal to sell liquor without a license in New Jersey, there was no evidence presented at trial proving that Mr. Sutton had actually sold any alcohol; he merely possessed it with intent to sell. Furthermore, Justice Holmes pointed out inconsistencies in how state laws were being applied - noting that if possession alone constituted an offense then every licensed seller would also be guilty under this interpretation since they too possess alcohol with intent to distribute or sell it as part of their business operations. Therefore, he believed Mr. Sutton’s conviction represented an unfair application of the law and advocated for his acquittal.