In United States v. Smith (1820) 18 U.S. 153, the Supreme court discussed the bases for universal jurisdiction over piracy. The issue was whether the Act of 1819's definition of piracy referencing the law of nations was within Congress' power to define and punish piracies. (18 U.S. at 158-60). Smith goes no further than holding that the Act of 1819's definition of piracy was a constitutional exercise of Congress' power to define piracies and that piracy is defined by the law of nations as robbery upon the sea. (Id. at 160-62.) The Smith Court examined over a dozen treatises in English, Latin, French, and Spanish, as well as English caselaw, and determined that these various sources all agreed upon the same basic definition of piracy under international law. Smith, (18 U.S. at 163-80.) Justice Story noted that, "whatever may be the diversity of definitions, . . . all writers concur, in holding, that robbery or forcible depredations upon the sea, animo furandi with the intention to steal is piracy." The common law, too, recognises and punishes piracy as an offence, not against its own municipal code, but as an offence against the law of nations, (which is part of the common law,) as an offence against the universal law of society, a pirate being deemed an enemy of the human race.