In the 1917 case Thompson, Administrator of Thompson v. United States, the Supreme Court ruled on a dispute over inheritance tax law. The plaintiff was the administrator of an estate that included bonds issued by foreign corporations but payable in U.S. dollars and held by American citizens at their death. The federal government sought to impose an inheritance tax on these assets under existing laws which taxed all property within the jurisdiction of the United States at time of death regardless if it is physically located elsewhere. The court had to determine whether such bonds were considered property "situated within" or "subject to" US jurisdiction for purposes of taxation despite being issued abroad and not physically present in America when their holders died. Ultimately, Justice Holmes delivered a unanimous decision stating that these types of securities are indeed subject to U.S. taxation because they represent obligations payable here and therefore have a situs for tax purposes where they can be enforced - i.e., within U.S jurisdiction.

In the dissenting opinion for Thompson v. United States, Justice Oliver Wendell Holmes Jr. argued that the majority's decision to uphold a conviction based on evidence obtained through an unauthorized search was fundamentally flawed. He contended that such searches violated citizens' Fourth Amendment rights against unreasonable searches and seizures, regardless of whether or not they led to the discovery of incriminating evidence. Holmes believed this ruling set a dangerous precedent by essentially allowing law enforcement officers to disregard constitutional protections in their pursuit of criminal convictions. Furthermore, he expressed concern about potential abuses of power if police were given free rein to conduct warrantless searches without any legal repercussions.