In the case of Franklin v. United States in 1909, the Supreme Court dealt with a dispute over land ownership. The plaintiff, Franklin, claimed that he had purchased a tract of land from an Indian tribe and sought to prevent the U.S government from taking possession of it. However, according to federal law at that time, only Congress could approve such transactions between Native American tribes and private individuals or entities. Since there was no evidence showing Congressional approval for this particular sale transaction between Franklin and the tribe involved in this case; therefore his claim was deemed invalid by lower courts. The Supreme Court upheld these rulings on appeal stating that without explicit congressional approval any purported sales agreement would be considered null and void under existing laws governing property rights involving Native American lands. This decision reinforced legal principles regarding tribal sovereignty as well as federal authority over matters related to indigenous affairs.

In the dissenting opinion for Franklin v. United States, Justice Harlan argued that the majority's decision to uphold a conviction based on evidence obtained through an illegal search and seizure was in direct violation of constitutional rights. He contended that such actions by law enforcement officials were not only unlawful but also threatened individual liberties protected under the Fourth Amendment. Harlan emphasized his belief that any evidence obtained illegally should be excluded from trial proceedings, regardless of its relevance or importance to the case at hand. This principle, he asserted, was fundamental to maintaining justice and upholding citizens' constitutional protections against unreasonable searches and seizures.