In United States v. Gale & Another, the Supreme Court of the United States was asked to decide whether the United States had the right to bring a criminal prosecution against two individuals for the alleged violation of a federal statute. The two individuals, Gale and another, had been charged with violating a federal statute that prohibited the sale of liquor without a license. The Supreme Court held that the United States had the right to bring a criminal prosecution against the two individuals. The Court reasoned that the federal statute in question was a valid exercise of Congress’s power to regulate commerce, and that the United States had the right to enforce the statute. The Court also held that the individuals had no right to challenge the validity of the statute in a criminal prosecution. In conclusion, the Supreme Court held that the United States had the right to bring a criminal prosecution against the two individuals for the alleged violation of a federal statute. The Court reasoned that the federal statute was a valid exercise of Congress’s power to regulate commerce, and that the United States had the right to enforce the statute. The Court also held that the individuals had no right to challenge the validity of the statute in a criminal prosecution.

Justice Field delivered the dissenting opinion in United States v. Gale & Another, arguing that the majority's decision was incorrect and should be reversed. He argued that Congress had not intended to limit its power of taxation by requiring a stamp on certain documents, but rather it had done so as an exercise of its constitutional authority to tax for revenue purposes. Furthermore, he asserted that if Congress did intend such a limitation then it would have been explicitly stated in the statute itself or elsewhere in law. Additionally, Justice Field maintained that even if there were some ambiguity regarding Congressional intent with regard to taxing documents without stamps, this ambiguity should be resolved against taxation since any doubt must be construed liberally when interpreting statutes involving taxes due from citizens. In conclusion, Justice Field concluded his dissent by stating "the judgment below should therefore be affirmed."