In the Matter of Heff, 1904, a man named John Heff was convicted in Oregon for selling liquor to Native Americans. The conviction was based on an act passed by Congress in 1897 that made it illegal to sell alcohol to any member of the Indian tribes within U.S. territory. However, Heff argued that this law did not apply because he sold liquor to Indians who were living outside their reservation and had severed tribal relations. The Supreme Court ruled against him stating that the Act applied regardless of whether or not they lived on reservations or maintained tribal relations. The court held that Congress has plenary power over Indian affairs under its constitutional authority "to regulate commerce with foreign nations and among several states and with Indian tribes." Therefore, it could prohibit sales of alcohol even if those transactions took place off-reservation between non-Indians and Indians who no longer maintain formal ties with a tribe.

The Matter of Heff case in 1904 did not have a recorded dissenting opinion. The Supreme Court unanimously ruled that the Secretary of the Interior has broad discretion to interpret and apply laws related to public lands, including those involving mining claims. In this particular case, it upheld his decision regarding a disputed gold claim in Alaska.