The U.S. Supreme Court case Alaska Pacific Fisheries v. United States in 1918 revolved around a dispute over fishing rights and land ownership in the Karluk Reservation, which was established for the benefit of native Alaskan tribes by Congress. The Alaska Pacific Fisheries company claimed that they had exclusive rights to fish in certain waters within this reservation due to prior use and occupancy before it became a reservation. However, the court ruled against them stating that when Congress created reservations, it intended to include all resources within those boundaries for the exclusive use of Native Americans living there unless explicitly stated otherwise. Therefore, even though Alaska Pacific Fisheries may have used these waters previously, once they were included within reservation boundaries their right ceased without explicit permission from Congress or compensation made to affected tribes.

In the dissenting opinion for Alaska Pacific Fisheries v. United States, Justice McReynolds disagreed with the majority's interpretation of the 1867 Treaty of Cession between Russia and America. He argued that this treaty did not grant exclusive fishing rights to Alaskan natives in Metlakatla Island waters. According to him, it was unreasonable to assume that Congress intended such a significant transfer of property rights without explicit language stating so in either the treaty or subsequent legislation. Furthermore, he believed that granting these exclusive rights would be inconsistent with American principles regarding public lands and resources' common use by all citizens. Thus, he contended that any special privileges granted to Alaskan natives should have been explicitly stated rather than inferred from ambiguous terms.