On appeal, the Supreme Court reversed and remanded again, ruling that the Chemical Weapons Convention Implementation Act of 1998 did not reach Bond's actions and she could not be charged under that federal law.

When Bond discovered that her husband was the child's father, she attempted to injure her former friend by putting organoarsenic and potassium dichromate on the woman's door knob.

Senator Ted Cruz wrote an essay for the blog of the Harvard Law Review, urging the Court to overturn Bond's conviction.

[7] In its judgment, the Court unanimously concluded that the convention was not meant to cover local activities such as Bond's poisoning attempt.

Writing for the Court, Chief Justice Roberts declined to define the scope of Treaty Clause powers, invoking constitutional avoidance.

Because the Chemical Weapons Convention is not self-executing and because it requires implementation by a signatory to be "in accordance with its constitutional processes," Roberts focused his attention on statutory interpretation of the federal criminal code.

According to Roberts, one of the key "background principles of construction" is federalism; there must be a "clear indication" by Congress if it intends to "dramatically intrude upon traditional state criminal jurisdiction."

[8] Finally, Roberts briefly responds to Justice Scalia's interpretation by noting that adopting "the most sweeping reading of the statute would fundamentally upset the Constitution's balance."

[13] Furthermore, an 1815 treaty could constitutionally pre-empt a South Carolina law authorizing the local kidnapping of free negroes because, according to Thomas, some of the sailors who were enslaved were British.