In the 1908 case of Woodwell v. United States, the Supreme Court was asked to determine whether a contract for the sale and delivery of intoxicating liquors in Indian Territory violated federal law prohibiting such sales. The defendant, Woodwell, had entered into a contract with an individual in Indian Territory for the sale and delivery of whiskey. He argued that since he did not personally deliver or sell liquor within Indian Territory but rather shipped it from Missouri via railway express company, he should not be held liable under federal law. The court disagreed with this argument and upheld his conviction. They found that even though Woodwell himself did not physically enter Indian territory to make the sale or delivery, his actions still constituted selling and delivering alcohol within those boundaries as prohibited by law. The court concluded that any act which contributes directly to accomplishing an unlawful purpose is considered partaking in said unlawful action itself - hence making him guilty.

In the dissenting opinion for Woodwell v. United States, it was argued that the defendant's conviction should be overturned due to a lack of evidence supporting his guilt beyond reasonable doubt. The dissenting justices believed that there were significant issues with how the lower courts had interpreted and applied the law in this case. They contended that a key piece of evidence - an alleged confession by Woodwell - was not sufficiently corroborated by other independent evidence to establish his guilt definitively. Furthermore, they criticized the trial court's instructions to jurors about what constituted sufficient corroboration, arguing these instructions were misleading and prejudicial against Woodwell. In their view, these errors undermined confidence in both Woodwell’s conviction and sentence.