In the United States v. Mossel case of 1922, the Supreme Court examined whether a U.S. citizen could be prosecuted for fraud committed while abroad. The defendant, Mr. Mossel, was charged with using mail and wire services to defraud investors in a foreign mining operation he controlled from his home in New York City. He argued that since the alleged fraudulent activities occurred outside of U.S territory (in Mexico), they were beyond American jurisdiction. The court disagreed with this argument and upheld his conviction on all counts except one - it ruled that federal law did not extend to cover false statements made by telegraph about assets located overseas unless those statements were also transmitted within the United States itself. This decision established an important precedent: although there are limits to its reach, U.S law can apply extraterritorially when crimes involve interstate or international communications systems based within America's borders.

In the dissenting opinion for United States v. Mossel, Justice Holmes argued that the defendant's conviction should be upheld because he believed that the evidence was sufficient to prove guilt beyond a reasonable doubt. He disagreed with the majority's interpretation of what constituted "reasonable doubt," stating that it was not necessary for every possible hypothesis of innocence to be disproven in order to secure a conviction. Instead, he contended that if all elements of an offense were proven and there existed no plausible theory of innocence based on those facts, then this would suffice as proof beyond a reasonable doubt. Furthermore, Holmes criticized his colleagues' decision as being overly cautious and potentially harmful to future prosecutions by setting an unreasonably high standard for proving guilt.