In Whitfield v. United States, the Supreme Court of the United States was asked to decide whether a defendant could be convicted of a crime if the indictment failed to allege the essential elements of the offense. The defendant, Whitfield, was charged with the crime of embezzlement from the United States. The indictment failed to allege that Whitfield had taken the money with the intent to defraud the United States. The Supreme Court held that the indictment was insufficient to support a conviction. The Court reasoned that the intent to defraud was an essential element of the crime of embezzlement, and that the indictment must allege this element in order to support a conviction. The Court further held that the indictment must be read as a whole, and that the failure to allege the essential element of intent to defraud was fatal to the indictment. The Court's decision in Whitfield v. United States established the principle that an indictment must allege all of the essential elements of the crime in order to support a conviction. This principle has been applied in numerous cases since then, and is an important part of criminal law in the United States.

Justice Field delivered the dissenting opinion in Whitfield v. United States, arguing that Congress had no authority to pass a law which would allow for the forfeiture of property without due process of law. He argued that this was an infringement on rights protected by the Fifth Amendment and therefore unconstitutional. Field further argued that if Congress were allowed to pass such laws, it could lead to arbitrary seizures and punishments with no legal recourse or protection for citizens who are wrongfully accused or convicted. Furthermore, he noted that there is nothing in either the Constitution or any other federal statute which grants Congress such power over private property; thus, he concluded that this particular act was beyond its constitutional powers and should be struck down as invalid.