In the United States v. Thomas case of 1893, the Supreme Court ruled on a matter involving maritime law and piracy. The defendants, Albert W. Thomas and others, were charged with mutiny aboard an American vessel while in international waters off the coast of Brazil. They had killed their captain and taken control of the ship before being apprehended by another U.S.-flagged ship that returned them to New York for trial. The defense argued that since they were not within U.S territory at the time of their crime, they could not be tried under U.S law; however, this argument was rejected by both lower courts and eventually by the Supreme Court as well. The court held that jurisdiction over crimes committed on American vessels in international waters falls under US federal law regardless of where such offenses occur or where offenders are apprehended. This ruling affirmed Congress's power to enact laws governing conduct aboard American ships in international waters.

In the dissenting opinion for United States v. Thomas, Justice Brewer argued that the court majority had erred in its interpretation of the law and overstepped its authority by imposing a tax on state banks' circulation of notes from national banks. He contended that this was not within Congress's power to regulate commerce or provide for fiscal operations, but rather an intrusion upon states' rights. Brewer believed it was unconstitutional to impose such a tax as it interfered with state banking systems and infringed upon their ability to operate freely under state laws. Furthermore, he expressed concern about potential implications if federal taxation were allowed to extend into areas traditionally controlled by states.