In the United States v. Martinez case of 1901, the Supreme Court ruled on a matter involving customs duties and territorial jurisdiction. The defendant, Martinez, had been charged with smuggling goods into Puerto Rico from France without paying required customs duties. He argued that since Puerto Rico was not officially considered a U.S territory at the time of his alleged crime (as it was under military occupation following the Spanish-American War), he should not be subject to U.S laws regarding importation and taxation. The Supreme Court disagreed with this argument, ruling that even though formal political control over Puerto Rico had yet to be established by Congress when Martinez committed his alleged offense, it still fell within U.S jurisdiction for purposes related to enforcing revenue laws. Therefore, according to their decision in this case, individuals could indeed be prosecuted under federal law for smuggling goods into territories occupied by American forces during wartime or other periods of transition.

In the dissenting opinion for United States v. Martinez, Justice Harlan argued that the majority's decision violated fundamental principles of justice and fairness. He contended that the government had no right to seize property without due process of law, even in times of war or insurrection. Furthermore, he believed that it was unconstitutional for Congress to delegate its power to declare forfeiture laws to military commanders during wartime. This delegation not only undermined civilian control over military affairs but also threatened individual liberties by allowing arbitrary seizures based on mere suspicion rather than concrete evidence or judicial proceedings. In his view, such actions were inconsistent with both constitutional safeguards against unreasonable searches and seizures as well as basic tenets of democratic governance.