In the 1912 case of Evans v. United States, the Supreme Court ruled on a matter involving land rights in Oklahoma. The plaintiff, Evans, had purchased land from an individual who was half Native American and half Caucasian but was not officially recognized as part of any tribe. Under existing law at that time, lands allotted to Native Americans were exempt from taxation for a period of twenty-one years unless they were sold or transferred before this period ended. However, because the seller wasn't officially recognized as part of any tribe when he received his allotment and later sold it to Evans within five years (which violated another statute), there arose a dispute over whether these tax exemptions applied. The court held that despite these circumstances, the exemption still applied since Congress intended for all such allotments - regardless if they're made to tribal members or non-members - to be free from taxes during their first twenty-one years unless prematurely terminated by sale or transfer under certain conditions which didn't apply here due to ambiguity surrounding seller's tribal status when he got his allotment.

In the dissenting opinion for Evans v. United States, Justice Holmes disagreed with the majority's interpretation of what constitutes a bribe under federal law. He argued that accepting money as an official does not automatically constitute bribery unless there is proof that the official altered his or her actions because of it. In this case, he believed there was no evidence to suggest that Evans had changed his behavior due to receiving money from another party and thus should not be convicted of bribery. Furthermore, he contended that if every gift or payment made to an official were considered a bribe, then many innocent transactions would be criminalized unfairly. Therefore, in order for someone to be guilty of bribery according to Holmes' interpretation, they must have accepted something with corrupt intent - meaning they intended their actions as an officer/official would change based on what they received.