In England, high treason can only be committed against ... before a Judge would venture to decide that an overt act of levying war had not been committed by a Commissary of purchases who never ...

In pursuance of the power thus conferred, Congress passed an act, which was approved ... of the Federal Government; it is high treason by levying war. Either one of those acts will constitute ...

High treason ... in the levying of war. Together, these cases made a treason conviction exceedingly difficult for anything other than manifest participation in a treasonable act.