In Francis v. United States, the Supreme Court of the United States was asked to decide whether a federal statute that prohibited the sale of liquor within four miles of an Indian reservation was constitutional. The Court held that the statute was constitutional, as it was within the scope of Congress’s power to regulate commerce with Indian tribes. The case arose when the defendant, Francis, was convicted of selling liquor within four miles of an Indian reservation in violation of the federal statute. Francis argued that the statute was unconstitutional because it was an unconstitutional exercise of Congress’s power to regulate commerce with Indian tribes. The Court disagreed, holding that Congress had the power to regulate commerce with Indian tribes, and that the statute was a valid exercise of that power. The Court noted that Congress had the power to regulate commerce with Indian tribes in order to protect them from the “evils of intemperance” and to promote their “civilization and improvement.” The Court held that the statute was a valid exercise of Congress’s power to regulate commerce with Indian tribes, and that it was not an unconstitutional infringement on the rights of individuals. In conclusion, the Supreme Court held that the federal statute prohibiting the sale of liquor within four miles of an Indian reservation was constitutional, as it was within the scope of Congress’s power to regulate commerce with Indian tribes.

Justice Field delivered the dissenting opinion in Francis v. United States, arguing that the majority's decision was contrary to both precedent and reason. He argued that Congress had no authority to pass a law which would allow for an individual who has been convicted of a crime to be released from prison without being pardoned by either the President or Governor of their state. Furthermore, he noted that such laws were not only unconstitutional but also dangerous as they could lead to individuals being released from prison before they have served their full sentences. In conclusion, Justice Field argued that if Congress wished for prisoners to be released early then it should do so through its power of pardon rather than passing legislation which is clearly unconstitutional and potentially dangerous.