In the 1910 case of Wise v. Henkel, the United States Supreme Court addressed a dispute between two government officials over extradition procedures. The petitioner, George W. Wise, was a U.S Attorney who sought to extradite an individual from New York to Washington D.C for trial on charges of conspiracy and bribery related to postal contracts. However, Edward S. Henkel, the U.S Marshal in New York refused to comply with this request as he believed that it violated federal law which required individuals be tried where their alleged crimes were committed. The Supreme Court ruled in favor of Wise stating that while generally defendants should be tried where they commit their crimes; exceptions can exist when dealing with conspiracies spanning multiple jurisdictions or involving federal officers performing duties outside their home districts. This decision clarified how jurisdictional rules apply in complex criminal cases and affirmed prosecutors' ability to bring defendants into any district implicated by a multi-district conspiracy charge.

In the dissenting opinion for Wise v. Henkel, Justice Harlan argued that the majority's decision was inconsistent with previous rulings and violated principles of federalism. He contended that a U.S. attorney does not have authority to order a U.S marshal to transport an individual across state lines without explicit authorization from Congress or the Constitution itself. Harlan believed this case represented an overreach of federal power into areas traditionally reserved for states, such as criminal procedure and extradition laws. Furthermore, he expressed concerns about potential abuses of power if federal officials were allowed to circumvent these state-level protections at their discretion.