A most interesting problem …, some years ago, engaged the attention of the courts of Georgia. A man named Simpson, standing in South Carolina, fired a pistol with felonious intent at a person who was in a boat, on water embraced within the territorial limits of Georgia. The bullets went wide of the person at whom they were aimed and splashed in the water. It was held by the courts that the defendant was guilty of an assault with intent to murder in Georgia, ‘because,’ said the judge, ‘the balls did strike the water of the river in close proximity to him (the prosecuting witness) within this State, and it is therefore certain that they took effect in Georgia.’

For the purposes of the case the judge held further that the defendant, when he fired the shots, was constructively in the State of Georgia. This holding was upon a theory of the law that where one puts in force an agency for the commission of crime, he, in legal contemplation, accompanies the same to the places where it becomes effectual.

— “Historic Legal Puzzles,” The Green Bag: A Useless but Entertaining Magazine for Lawyers, August 1899