In the United States v. Winslow case of 1912, the Supreme Court ruled on a matter concerning federal jurisdiction over crimes committed in unincorporated territories of the U.S., specifically Alaska. The defendant, Winslow, was charged with manslaughter for killing a man while both were within an area not incorporated into any judicial division or district of Alaska. He argued that since his crime occurred outside established jurisdictions, he could not be prosecuted under federal law. However, the court disagreed and upheld his conviction by asserting that Congress had intended to extend its laws to all parts of Alaska when it passed legislation governing this territory in 1884 and 1900. Therefore, even though certain areas may not have been formally incorporated into specific districts at those times due to their remoteness or sparse population density; they were still subject to federal law enforcement.

In the dissenting opinion for United States v. Winslow, the justice argued that there was a significant difference between an act of Congress and a regulation made by an executive department or officer under powers conferred by Congress. The latter, he believed, could not be considered as having equal weight to actual legislation passed by Congress itself. He further contended that while it is true that regulations can have legal effect when they are within the scope of authority granted to them, they cannot extend beyond what has been expressly authorized in law or necessarily implied from such authorization. In this case, he felt that the Secretary of Agriculture had overstepped his bounds with his interpretation and application of certain provisions related to timber reserves on public lands - specifically those concerning trespasses and depredations committed against these reserves - which were at issue in this case.