In the case of Lane, Secretary of the Interior, v. United States ex rel. Mickadiet and Tiebault (1915), the U.S Supreme Court was asked to decide on a land dispute involving mining claims in Alaska. The appellants claimed that they had complied with all necessary requirements for their claim under federal law; however, their application was rejected by the Secretary of Interior who argued that there were discrepancies in their filings and they failed to provide sufficient evidence proving discovery of valuable mineral deposits as required by law. The court ruled in favor of the government stating that it is within its rights to demand strict compliance with laws governing public lands including proof beyond reasonable doubt about existence of valuable minerals before granting any mining claims.

In the dissenting opinion for Lane v. United States ex rel. Mickadiet and Tiebault, Justice Holmes argued that the majority's decision to deny citizenship to Native Americans who had not formally severed their tribal relations was incorrect. He believed that this interpretation of the law was too narrow and failed to consider broader societal changes regarding attitudes towards Native American citizenship rights. Furthermore, he contended that it was unjust to require individuals born within U.S territory, such as these petitioners who were born on a reservation in Michigan, to take additional steps beyond those required of other native-born citizens in order to be recognized as such by the government.