In the United States v. Plowman case of 1909, the Supreme Court examined whether a federal statute that prohibited sending threatening letters through mail could be applied to threats made against a third party. The defendant, Mr. Plowman, had sent a letter to his wife in which he threatened to kill another man with whom she was allegedly having an affair. He was subsequently charged and convicted under this federal law for mailing such threats. The Supreme Court overturned his conviction on appeal, ruling that the language of the statute only covered direct threats against recipients of mailed letters and not indirect ones against other individuals who were not intended recipients of those communications. Therefore, since Mr. Plowman's threat was directed at someone other than his wife (the recipient), it did not fall within the scope of this particular law.

The dissenting opinion in the United States v. Plowman case argued that the defendant, who was charged with selling liquor without a license on an Indian reservation, should not be held liable under federal law because he had obtained a state license to sell alcohol. The dissenting justices contended that since the offense occurred within a state and not on "Indian country," it fell outside of federal jurisdiction. They further asserted that even if it were considered "Indian country," there was no evidence presented proving this fact beyond reasonable doubt as required by law for conviction. Therefore, they believed the judgment against Plowman should have been reversed due to lack of sufficient proof and improper application of jurisdictional laws.