In the 1890 case of Halsted v. Buster, the U.S. Supreme Court dealt with a dispute over land titles in Kansas. The plaintiff, Halsted, claimed that he had purchased certain lands from an individual who had acquired them through preemption rights under federal law. However, the defendant Buster argued that these lands were part of an Indian reservation and thus not subject to preemption or private ownership at all until Congress passed legislation opening them up for settlement by non-Indians. The court ruled in favor of Buster on two grounds: Firstly, it found that when Congress established reservations for Native American tribes via treaties or statutes, those lands are withdrawn from public domain and cannot be preempted by settlers unless explicitly allowed by Congress; Secondly, even if there was ambiguity about whether specific parcels fell within reservation boundaries (as was alleged here), such doubts must be resolved in favor of indigenous peoples due to their vulnerable position vis-a-vis settler colonialism. This decision reaffirmed both tribal sovereignty over reserved territories as well as Congressional power to regulate disposition thereof - principles which remain central tenets of Federal Indian Law today.

In the dissenting opinion for Halsted v. Buster, it was argued that the majority's decision to uphold a lower court ruling in favor of Buster contradicted established legal principles regarding land ownership and transfer. The dissenting justices believed that Halsted had a valid claim to the disputed property because he had purchased it from someone who held a legitimate title at the time of sale. They contended that this should have been sufficient to establish his right to ownership, regardless of any subsequent changes in circumstances or claims by other parties. Furthermore, they disagreed with the majority's interpretation of relevant statutes and case law, arguing instead for an approach which would prioritize protecting innocent purchasers against unforeseen challenges to their titles. In essence, they felt that upholding such challenges could undermine confidence in property transactions more broadly.