 The first two decisions to interpret § 8 construed it not to apply to the crimes charged . In United States v. Bevans ( 1818 ) , the Court held that the § 8 of the Act did not extend to a murder committed on a navy vessel within state waters . In United States v. Palmer ( 1818 ) , the Court held that the § 8 of the Act did not extend to piracy by U.S. citizen defendants , in the employ of a South American government at war with Spain , committed against Spanish ships and citizens . President John Quincy Adams was a harsh critic of the decision in Palmer . He wrote in his diary that the Court had " cast away the jurisdiction which a law of congress had given , that its " reasoning [ was ] a sample of judicial logic — disingenuous , false , and hollow , " and that it gave him " an early disgust for the practice of law , and led me to the unalterable determination never to accept judicial office . " 
