In the case of In re Morrison, 1892, the petitioner was a lawyer who had been disbarred by the Supreme Court of Utah Territory. The court's decision to disbar him was based on his alleged misconduct in handling client funds. He appealed this decision to the U.S. Supreme Court arguing that he did not receive fair treatment and due process from the lower court because they failed to provide him with an opportunity for defense before disbarring him. The U.S. Supreme Court ruled against Morrison stating that while it is true every individual has a right to practice their profession without interference unless proven guilty of misconduct, courts also have inherent power over attorneys practicing within their jurisdiction which includes disciplining them when necessary for protection of courts and administration of justice. Therefore, if there are reasonable grounds showing attorney’s unfitness or dishonesty in professional conduct then it becomes duty of court itself irrespective whether complaint has been made or not; hence no formal notice or hearing is required before disbarring such person as long as facts justifying action are placed on record.

The dissenting opinion in the case of In re Morrison, 1892, argued that the court's decision to deny a writ of habeas corpus was incorrect. The dissenting justices believed that Morrison had been unlawfully detained and his constitutional rights violated. They contended that the federal government did not have jurisdiction over crimes committed on Indian reservations unless explicitly granted by Congress. Therefore, they asserted that since no such grant existed at the time of Morrison's arrest for murder on an Indian reservation, he should be released from custody immediately. Furthermore, they disagreed with majority’s interpretation of existing treaties and laws regarding Native American sovereignty and criminal jurisdiction within their territories. This disagreement stemmed from differing views about whether these legal instruments implicitly gave federal courts authority over serious crimes committed by non-Indians on reservations or if explicit congressional action was required to establish such authority.