In the United States v. Lewis case of 1914, the Supreme Court ruled on a matter involving mail fraud. The defendant, Lewis, was accused of using the U.S Postal Service to defraud individuals by promising them employment in exchange for payment but failing to provide said employment after receiving their money. He argued that his conviction should be overturned because he had not been indicted by a grand jury as required under the Fifth Amendment and instead had been charged via information filed by a district attorney. However, this argument was rejected due to an exception in federal law allowing prosecution for misdemeanor offenses without indictment from a grand jury if they are punishable only with fines or imprisonment for less than one year or both (which applied here). Therefore, it was held that there was no violation of constitutional rights and Lewis' conviction stood.

In the dissenting opinion for United States v. Lewis, it was argued that the defendant's conviction should be upheld because he knowingly and willingly committed fraud against a bank. The dissenting justices believed that there was sufficient evidence to prove that Lewis had intentionally deceived the bank by misrepresenting his financial status in order to secure loans. They disagreed with the majority's interpretation of "intent to defraud" under federal law, arguing instead for a broader understanding of this term which would include any deliberate act of deception aimed at securing an unfair or unlawful gain. According to them, such acts are inherently fraudulent and should therefore be punishable under federal law regardless of whether they result in actual harm or loss.