In the case of Williams v. United States in 1897, the Supreme Court ruled on a matter concerning maritime jurisdiction and criminal law. The defendant, Mr. Williams was convicted for manslaughter committed on an American vessel while it was docked at a foreign port (Yokohama, Japan). He appealed his conviction arguing that U.S courts did not have jurisdiction over crimes committed in foreign territories even if they occurred aboard American vessels. However, the Supreme Court upheld his conviction stating that under international law and U.S statutes such as Section 5339 of Revised Statutes which extends federal laws to American ships in foreign waters; U.S courts indeed had jurisdiction over crimes occurring aboard its flagged vessels regardless of their location globally. This ruling affirmed that US sovereignty extended to its citizens or property abroad when permitted by international agreements or principles.

In the dissenting opinion for Williams v. United States, Justice Harlan argued that the majority's decision to uphold a law allowing federal courts in Alaska to apply "any rule of common law" was too broad and potentially unconstitutional. He contended that this provision could be interpreted as giving these courts power beyond what is constitutionally permitted for any court - state or federal. Furthermore, he expressed concern about potential abuses of such wide-ranging authority by judges who might use it arbitrarily or capriciously. Harlan also disagreed with the majority's view that Congress had intended to grant such extensive powers when it passed legislation establishing a judicial system in Alaska; instead, he believed they meant only to allow those courts to follow general principles of common law where no specific statutes existed.