In the United States v. Gudger case of 1918, the Supreme Court ruled on a matter concerning federal jurisdiction over crimes committed in certain territories. The defendant, Gudger, was charged with murder that occurred within the Great Smoky Mountains National Park and argued that his trial should be held in state court rather than federal court because North Carolina had not ceded jurisdiction to the U.S. government when it transferred land for creation of this national park. However, under an Act of Congress from 1897 which stated any crime committed on lands acquired by U.S for public purposes would fall under federal jurisdiction unless explicitly reserved by states during transfer process - North Carolina hadn't made such reservation while transferring land for this park's establishment. Therefore, despite being located within state boundaries, crimes occurring there were subject to federal law enforcement and prosecution as per this act's provisions.

In the dissenting opinion for United States v. Gudger, Justice Holmes argued that the defendant's conviction should be overturned due to a lack of evidence supporting his alleged intent to defraud. He contended that while there was proof of false statements made by Gudger in relation to his claim for disability benefits from the government, it did not necessarily imply an intention to deceive or cheat. The mere fact that he lied about being unable to work and earn money does not conclusively prove fraudulent intent as required under law; it could simply mean he was mistaken or misinformed about what constitutes disability. Therefore, according to Justice Holmes, without clear evidence demonstrating such intent beyond reasonable doubt - which is absent in this case - no crime has been committed warranting punishment.