In Crain v. United States, the Supreme Court ruled on a case involving the interpretation of an act that provided for the sale of certain lands in Alabama to pay off Creek Indian debts. The plaintiff, Crain, claimed ownership over these lands based on a purchase from two Creek Indians who had received allotments under this act. However, there was a clause in the act which stated that these lands could not be sold or transferred without consent from Congress until after 1891. The government argued that this restriction applied even if it wasn't explicitly mentioned in individual land grants and thus invalidated Crain's claim to ownership. On appeal to the Supreme Court, it was held that while such restrictions were indeed part of general legislation regarding Native American land rights at this time period; they did not apply when they weren't specifically included within individual acts like this one. Therefore, since no such restriction was present within the specific text of this particular Act concerning Creek Indian Lands - despite being common practice elsewhere - it didn’t apply here and couldn’t invalidate Crain’s claim to his purchased property.

In the dissenting opinion for Crain v. United States, it was argued that the defendant's constitutional rights were violated due to an improper jury instruction. The judge instructed the jury that they could find the defendant guilty if they believed beyond a reasonable doubt that she had committed perjury, even though there was no direct evidence of this crime. The dissenting justices contended that this instruction effectively shifted the burden of proof from prosecution to defense and allowed for conviction based on suspicion or conjecture rather than concrete evidence. They maintained that such instructions undermined fundamental principles of justice by allowing juries to convict without sufficient proof, thereby violating defendants' right to be presumed innocent until proven guilty beyond a reasonable doubt.