In Christie v. United States (1914), the U.S Supreme Court ruled on a case involving an individual, Mr. Christie, who was charged with selling liquor to Native Americans in violation of federal law. The defendant argued that he had sold alcohol to individuals who were no longer "Indians" as defined by the statute because they had severed tribal relations and adopted habits of civilized life. However, the court rejected this argument stating that being an Indian is not solely determined by lifestyle or affiliation but also includes racial aspects; thus those individuals remained Indians under the law regardless of their assimilation into mainstream society. Therefore, Mr.Christie's actions were deemed illegal and his conviction upheld.

In the dissenting opinion for Christie v. United States, Justice Holmes argued that the defendant's conviction should be upheld. He disagreed with the majority's interpretation of what constituted a "lottery" under federal law, asserting that it was not necessary for a game to have all three traditional elements (prize, chance and consideration) in order to qualify as such. In his view, any scheme which distributed prizes based on luck rather than merit could potentially fall within this definition. Furthermore, he contended that Congress had broad authority to regulate interstate commerce and therefore could prohibit lottery tickets from being transported across state lines even if they were legal in their place of origin or destination. Finally, he expressed concern about judicial overreach and cautioned against second-guessing legislative decisions without clear constitutional grounds.