In White v. United States, the Supreme Court ruled that a state court's decision to convict an individual of treason was not subject to review by the federal courts. The case involved William H. White, who had been convicted in a Virginia State court for conspiring with Confederate forces during the Civil War and sentenced to death. He argued that his conviction violated his rights under Article III of the Constitution because it did not involve two witnesses or a confession in open court as required for convictions of treason against the United States government. However, Chief Justice Salmon P Chase wrote on behalf of unanimous opinion that since there is no provision in Article III which grants jurisdiction over state criminal proceedings involving treasonous acts committed against another sovereign power (in this case, Virginia), such cases are beyond federal judicial review and must be decided solely by state courts according to their own laws and procedures governing criminal trials within their jurisdictions.

In White v. United States, the Supreme Court was tasked with determining whether a federal statute that prohibited citizens from trading in goods with Confederate states during the Civil War was constitutional. The majority opinion held that Congress had acted within its authority to regulate commerce and protect national security when it passed this law. However, Justice Nelson dissented on the grounds that Congress did not have such broad powers under the Constitution and argued instead for a more limited interpretation of congressional power over interstate commerce. He maintained that while Congress could certainly prohibit trade between Union and Confederate states, it should not be able to interfere with private contracts or impose criminal penalties for violations of these laws without clear authorization from either an act of Congress or some other provision in the Constitution itself.