The Hot Springs Cases, also known as Rector v. United States, was a landmark Supreme Court case that dealt with the issue of Native American sovereignty. The case centered around the Hot Springs Reservation in Arkansas, which had been set aside by the federal government for the use of the local Native American tribes. The state of Arkansas had attempted to tax the reservation, claiming that it was not subject to the same laws as the rest of the state. The Supreme Court ruled that the reservation was indeed subject to the laws of the state, but that the federal government had the right to protect the reservation from state interference. The Court also held that the federal government had the right to regulate the reservation, and that the tribes had the right to self-governance. The decision was a major victory for Native American rights, and it established the principle that the federal government had the power to protect Native American sovereignty.

In the Hot Springs Cases, Rector v. United States, the Supreme Court was asked to decide whether Congress had authority under the Property Clause of the Constitution to set aside public lands for a reservation in Arkansas. The majority opinion held that Congress did have such power and could create reservations on public land without state consent or approval. However, Justice Field dissented from this decision and argued that while Congress may have some powers over federal property within a state's borders, it does not possess plenary power over all matters related to those properties. He further argued that if Congress were allowed unfettered discretion with regard to these lands then states would be deprived of their sovereignty and rights as guaranteed by both the Tenth Amendment and Article IV Section 3 of the Constitution which grants exclusive jurisdiction over certain areas within each state's boundaries. In conclusion, Justice Field believed that allowing Congressional control over these lands would violate both constitutional principles as well as long-standing legal precedents regarding states' rights versus federal authority