In the case of Woodward v. United States et al., 1950, the U.S Supreme Court upheld a lower court's decision to deny a writ of habeas corpus for an individual who had been convicted by a military tribunal during World War II. The petitioner, Woodward, was not in active service but held reserve status when he committed crimes against civilian and military laws while on furlough. He argued that his trial should have taken place in civil courts rather than before a military tribunal because he was technically not on active duty at the time of his offenses. However, the Supreme Court ruled that since Woodward still maintained some form of connection with the armed forces (even though inactive), it was within its jurisdiction to try him under martial law due to war circumstances.

In the dissenting opinion for Woodward v. United States, Justice Douglas argued that the majority's decision was a departure from established principles of law regarding criminal intent. He contended that in order to be guilty of aiding and abetting a crime, one must have knowledge of the illegal act and intend to participate or contribute to it. In this case, he believed there was insufficient evidence to prove that Woodward had such knowledge or intent when she sold alcohol on an Indian reservation without a license - her actions were not inherently wrong but only became so because they occurred on tribal lands where selling alcohol is prohibited by federal law. Therefore, according to Justice Douglas' interpretation of aiding and abetting laws, Woodward should not have been found guilty as charged.