The United States v. Evans was a Supreme Court case in which the defendant, John Evans, was accused of violating an act of Congress that prohibited trading with enemies during wartime. The government argued that by trading with French citizens on the island of St. Domingo while it was under British occupation, he had violated this law and should be punished accordingly. However, Evans contended that since France and Britain were not officially at war when he made his trades, there could be no violation as defined by the statute. In its decision, the court sided with Evans and held that because there had been no formal declaration of war between France and Britain at the time in question, any trade conducted would not constitute a violation according to Congress' intent for this particular statute. As such they ruled in favor of Evan's acquittal from all charges brought against him due to lack evidence proving otherwise

In the United States v. Evans, Justice Johnson wrote a dissenting opinion in which he argued that the majority's decision was contrary to law and precedent. He noted that Congress had not given any authority for the government to bring suit against individuals who were alleged to have committed crimes on Indian lands, as it did in this case. Furthermore, he argued that there was no evidence presented at trial of any criminal act having been committed by Evans on Indian land or otherwise within federal jurisdiction; thus, his conviction should be overturned because it violated due process rights under Article III of the Constitution. Additionally, Johnson pointed out that even if such an offense had occurred within federal jurisdiction—which he believed could only occur through congressional action—the court still lacked authority to try him since Congress had not provided for such proceedings either explicitly or implicitly in its legislation governing Indians and their territories. Finally, Justice Johnson concluded by noting that while Congress may have intended for offenses occurring on Indian lands to be tried before a jury of peers from those same lands (as opposed to being tried before a jury composed solely of citizens from other states), this intention was never made explicit nor codified into law; therefore it could not serve as grounds for convicting Evans without violating his right to due process under Article III of the Constitution