The United States v. Holmes et al. was a case heard by the Supreme Court in 1820 that involved a dispute over ownership of two vessels, the schooner Exchange and the sloop Little Sarah. The government had seized both ships for alleged violations of customs laws, but John Holmes and other claimants argued they were entitled to them as owners or part-owners under maritime law. After hearing arguments from both sides, Chief Justice Marshall delivered an opinion on behalf of the court affirming that while there may have been some irregularities in how title to these vessels passed between parties prior to their seizure by federal authorities, it was ultimately up to Congress—not courts—to decide who should be awarded possession of them. Ultimately, Congress decided not to award either party with possession and instead sold off both ships at auction for public revenue purposes; however this decision did not affect any underlying legal issues raised during trial which remain unresolved today

In the case of The United States v. Holmes et al., Chief Justice John Marshall delivered a dissenting opinion in which he argued that Congress had exceeded its authority by enacting an act to punish individuals for piracy on the high seas, as this was an offense traditionally within the jurisdiction of state courts. He further argued that such acts were unconstitutional because they violated Article III Section 2 of the Constitution, which states that "the trial of all crimes...shall be held in State." Furthermore, Marshall believed that if Congress could pass laws punishing offenses against international law without any constitutional basis or authority from a treaty with another nation, then it would have unlimited power and no limits to its legislative reach. In conclusion, Marshall maintained his belief that only state courts should have jurisdiction over cases involving piracy on the high seas and thus concluded his dissent from majority opinion.