In the case of Goldsby, Alias Cherokee Bill v. United States (1895), the U.S. Supreme Court ruled on a matter involving jurisdiction over crimes committed in Indian Territory. The defendant, Crawford Goldsby alias Cherokee Bill, was convicted and sentenced to death for murder by a federal court in Fort Smith, Arkansas. He appealed his conviction arguing that because he was an Indian who had killed another Indian within the boundaries of an established reservation (Indian Territory), only tribal courts held jurisdiction over his crime under existing treaties between tribes and the federal government. The Supreme Court disagreed with this argument stating that Congress had plenary power over all territories belonging to the United States including those designated as "Indian Country." It further clarified that while certain rights were granted to Native American tribes through treaties, these did not include sovereignty or exclusive judicial authority within their reservations unless explicitly stated so by Congress. Therefore it upheld Goldsby's conviction and sentence ruling that federal courts did have jurisdiction over serious crimes like murder committed in Indian Territory regardless of whether both victim and perpetrator were Indians.

In the dissenting opinion for Goldsby v. United States, Justice Brewer argued that the federal government did not have jurisdiction over crimes committed by one Native American against another on tribal land. He contended that Congress only had authority to regulate commerce with Indian tribes and manage their affairs but could not interfere in criminal matters within a tribe unless explicitly granted such power by treaty or legislation. The majority's interpretation of the law, according to him, undermined tribal sovereignty and self-governance. Furthermore, he disagreed with the majority's reliance on precedents involving non-Indians committing crimes on reservations as these cases were fundamentally different from those involving intra-tribal disputes among Indians themselves.