In the United States Supreme Court case of The United States v. Juan Manuel Vaca and Juan Felipe Pena, two men were charged with piracy for their involvement in a mutiny on board a Spanish vessel. The defendants argued that they had not committed any crime because they had acted under orders from the captain to take control of the ship due to his mistreatment of them. However, the court found that even if this was true, it did not excuse their actions as piracy is defined by international law as an act done without lawful authority or justification. Ultimately, the court ruled against Vaca and Pena and held them liable for their actions despite any mitigating circumstances surrounding them at the time of committing these acts.

The United States Supreme Court heard the case of The United States v. Juan Manuel Vaca and Juan Felipe Pena in 1855. In this case, two men were accused of murdering a fellow crew member on board a Spanish vessel while it was docked in the port of New Orleans. Justice Curtis delivered the dissenting opinion, arguing that because Louisiana had not yet been admitted to statehood at the time of the incident, federal jurisdiction did not extend to criminal cases occurring within its borders. He argued that since there was no law or treaty between Spain and America which provided for such jurisdiction over crimes committed by foreign nationals aboard ships docked in American ports, then any attempt by Congress to exercise authority over such matters would be unconstitutional as it exceeded their delegated powers under Article I Section 8 Clause 10 (the Necessary & Proper Clause). Furthermore he argued that even if Congress had passed legislation granting them power over these types of incidents they could only do so with respect to those states who have already joined union; thus making any action taken against Vaca and Pena invalid due to Louisiana's lack thereof at this time period.