In the case of Garfield, Secretary of the Interior v. United States ex rel. Goldsby in 1908, the Supreme Court ruled on a dispute over land rights and mineral deposits in Oklahoma. The plaintiff, Goldsby, claimed that he had discovered valuable asphalt deposits on public lands and sought to obtain mining rights under federal law. However, his application was denied by James R. Garfield as Secretary of the Interior who argued that these lands were reserved for use by Native American tribes under previous treaties with the U.S government. The court sided with Garfield's interpretation stating that while general laws are presumed to apply equally across all territories unless specifically exempted; this presumption does not hold when it comes to Indian reservations which have always been treated as exceptions due to their unique status within US legal framework. Therefore any ambiguity regarding whether such laws applied should be resolved in favor of tribal interests rather than private individuals or corporations seeking commercial exploitation. This decision reaffirmed earlier precedents recognizing tribal sovereignty and protecting native lands from unauthorized encroachment or resource extraction.

In the dissenting opinion for Garfield v. United States ex rel. Goldsby, Justice Harlan disagreed with the majority's decision to deny Goldsby's claim on a piece of land in Oklahoma that he had been living and working on for several years prior to its official opening for settlement by President Roosevelt in 1901. He argued that under the Homestead Act of 1862, any citizen who was head of a family or over twenty-one could lay claim to up to 160 acres of public land provided they lived on it and improved it through cultivation or building a dwelling within five years. According to Justice Harlan, since Goldsby met these requirements before anyone else claimed this particular parcel, his right should have been recognized despite not having filed an application at exactly the moment when registration opened as required by additional regulations imposed by Secretary Hitchcock in preparation for Oklahoma’s opening day.