In United States v. Cutting, the Supreme Court ruled that a defendant could not be convicted of an offense if the indictment failed to allege all essential elements of the crime. The case involved two defendants who were indicted for violating a federal statute prohibiting any person from knowingly and willfully obstructing or retarding "the passage of mail matter." The indictment alleged only that they had obstructed such passage without specifying how it was done. The Supreme Court held that this was insufficient because it did not state what acts constituted obstruction as required by law; thus, their convictions must be reversed and set aside. This decision established an important precedent in criminal procedure: indictments must include all essential elements of a crime in order to sustain a conviction against someone accused thereof.

In United States v. Cutting, the Supreme Court was asked to decide whether a federal court had jurisdiction over a case involving an alleged violation of state law. The majority opinion held that the federal court did not have jurisdiction because it was a matter of local concern and should be handled by state courts. Justice Field dissented from this decision, arguing that Congress had given the federal courts exclusive authority to hear cases arising under any laws made in pursuance of their constitutional powers, including those concerning matters traditionally within the purview of states. He argued further that if Congress intended for such matters to remain exclusively with state courts then they would have explicitly stated so in their legislation rather than leaving it open-ended as they did here. In conclusion, Field asserted that since there is no clear indication otherwise from Congress' language or intent regarding this issue, he believed it should be left up to each individual circuit court judge's discretion when deciding whether or not they could exercise jurisdiction over these types of cases.