In the United States v. Johnson case of 1898, the Supreme Court ruled on a matter concerning maritime law and jurisdiction. The defendant, Johnson, was charged with manslaughter after killing another man while aboard an American vessel in Japanese waters. He argued that U.S courts did not have jurisdiction over crimes committed in foreign territories or waters under international law principles of territorial sovereignty. However, the court disagreed and held that U.S laws were applicable to its citizens even when they are abroad if their actions affect other Americans or American interests. Therefore, it concluded that federal courts had jurisdiction over such cases involving criminal offenses committed by Americans on American vessels in foreign waters.

In the dissenting opinion for United States v. Johnson, 1898, Justice Harlan argued that the majority's interpretation of the law was too narrow and failed to consider its broader implications. He believed that Congress had intended to include all types of fraud within its purview when it passed legislation criminalizing fraudulent activities against the government. The majority's decision to exclude certain forms of fraud from this definition undermined Congressional intent and limited the scope of federal anti-fraud laws in a way that could potentially allow criminals to escape prosecution. Furthermore, he contended that their interpretation contradicted previous court rulings on similar cases which upheld a more expansive view of what constitutes fraud against the government.