In the case of United States v. Adams Express Company, 1912, the Supreme Court was tasked with determining whether a corporation could be held criminally liable for actions taken by its agents. The Adams Express Company had been indicted under an act that made it illegal to transport lottery tickets across state lines. An agent of the company transported such tickets without knowledge or approval from higher-ups in the company hierarchy. The court ruled that corporations can indeed be held responsible for criminal acts committed by their agents within the scope of their employment, even if those acts were not authorized or known about by management. This ruling established important precedent regarding corporate liability and responsibility.

In the dissenting opinion for United States v. Adams Express Company, the justice disagreed with the majority's interpretation of a statute that imposed taxes on corporations' net income derived from business activities. The justice argued that this tax should not apply to dividends received by one corporation from another because such dividends are not profits generated directly from doing business but rather passive income resulting from ownership stakes in other companies. He contended that Congress intended to tax only those incomes directly earned through active engagement in commerce or trade and did not intend to include dividend income within its purview. Therefore, he believed it was incorrect for the court majority to interpret otherwise and impose an additional layer of taxation on corporate shareholders who already bear their proportionate share of corporate taxes paid by corporations they own shares in.