In the 1893 case of Coleman v. United States, the U.S Supreme Court ruled on a matter concerning land patents and property rights. The plaintiff, Coleman, claimed that he had been unjustly deprived of his mining claim by an erroneous decision made by the Land Department which granted a patent to another party for part of his claim. He sought to have this decision overturned in court but was unsuccessful at both district and circuit levels as they refused jurisdiction over cases involving decisions from executive departments like the Land Department. Upon reaching the Supreme Court, it held that while courts generally do not interfere with decisions made by executive departments unless there is evidence of fraud or mistake; in this instance where private property rights were involved - specifically those acquired under laws enacted for their protection - judicial intervention was necessary to prevent potential injustice caused due to administrative error or oversight.

In the dissenting opinion for Coleman v. United States, Justice Brewer argued that the federal government had no jurisdiction over crimes committed in Indian Territory unless they involved non-Indians or were specifically mentioned in treaties with tribes. He believed that Congress' power to regulate commerce with Native American tribes did not extend to criminal matters within tribal lands and was limited by respect for tribal sovereignty. The majority's interpretation of the Major Crimes Act as applying to all serious offenses committed by Indians against other Indians, regardless of whether those crimes were listed in a treaty, was seen as an unwarranted expansion of federal authority into areas traditionally governed by tribal law. This view held that such intrusion undermined Native American self-governance and disregarded their rights as separate nations within U.S borders.