In the 1917 case of Ex parte Park & Tilford, the U.S. Supreme Court dealt with a petition for habeas corpus by Park & Tilford, a corporation involved in the liquor business in New York. The company was indicted under federal law for unlawfully and knowingly selling and giving away intoxicating liquors within an Indian reservation in New York state. They argued that they were not subject to this law as it applied only to "Indian country," which did not include reservations located within states like New York where Indians had become citizens and their lands were under state jurisdiction. The court denied their petition, ruling that even though these areas might be under general state jurisdiction, they still constituted "Indian country" as per federal laws regulating trade with Native American tribes. Therefore, such laws could apply to actions taken on those lands regardless of whether or not they are located within a particular state's boundaries or if its residents have gained citizenship status.

The dissenting opinion in the Ex parte Park & Tilford case argued that the court should not have jurisdiction over this matter. The justice believed that it was inappropriate for a federal court to intervene in a state's internal affairs, particularly when it came to matters of taxation. They contended that states had the right to levy taxes as they saw fit and if there were any issues with these taxes, those concerns should be addressed within the state itself rather than being brought before a national body like the Supreme Court. This perspective emphasized respect for states' rights and autonomy, arguing against what they viewed as an unnecessary intrusion by federal authorities into local governance.