In the case of Williams v. United States in 1890, the U.S Supreme Court ruled on a matter involving maritime jurisdiction and criminal law. The defendant, Mr. Williams was accused of murdering another American citizen while both were aboard an American ship docked at a foreign port (in this instance, Peru). He was tried and convicted in California under federal law which allowed for prosecution of crimes committed against Americans on American vessels abroad. However, he appealed his conviction arguing that U.S courts did not have jurisdiction over crimes committed within territorial waters of another nation. The Supreme Court upheld his conviction stating that the location where the crime occurred fell under "special maritime and territorial jurisdiction" as per US laws even though it happened within Peruvian territory because they were onboard an American vessel when it took place. This ruling affirmed that U.S courts could exercise extraterritorial jurisdiction over certain crimes committed by or against its citizens abroad.

In the dissenting opinion for Williams v. United States, Justice Lamar argued that Congress did not have the constitutional authority to regulate commerce within a territory as it does between states or with foreign nations. He contended that territories are not sovereign entities like states but rather possessions of the federal government, and therefore should be subject to different rules regarding commerce regulation. Furthermore, he asserted that if Congress were allowed such broad regulatory power over territories' internal affairs, it could potentially lead to abuses of power and infringement on individual rights. Justice Lamar also expressed concern about potential implications for state sovereignty if this interpretation of congressional powers was accepted.