In Miller's Heirs v. M'Intire & Others, the Supreme Court of the United States was asked to determine whether a state court had jurisdiction over an action brought by citizens of another state against defendants who were also citizens of that other state. The plaintiffs argued that they should be allowed to bring their suit in a federal court because it involved parties from different states and thus fell under the purview of Article III, Section 2, Clause 1 (the Diversity Clause) of the U.S. Constitution which grants federal courts original jurisdiction in such cases. The Supreme Court disagreed with this argument and held that while Congress has authority to grant federal courts exclusive jurisdiction over certain types of cases involving diversity between states, it did not do so here; therefore, only state courts have jurisdiction over such matters unless otherwise provided for by Congress or treaty stipulations between two or more states.

In Miller's Heirs v. M'Intire & Others, the Supreme Court was asked to decide whether a deed of land made by an Indian tribe in 1785 had been validly executed and conveyed title to the purchasers. The majority opinion held that it did not because there was no evidence that the Indians understood what they were doing when they signed away their rights to their lands; however, Justice Story dissented from this view. In his dissent, he argued that although there may have been some uncertainty as to whether or not the Indians fully comprehended what they were signing away at the time of execution, this should be irrelevant since all parties involved acted in good faith and with due diligence throughout negotiations leading up to and following execution of said deed. Furthermore, Justice Story noted that if such transactions are invalidated on grounds other than fraud or duress then it would create instability for future dealings between settlers and Native Americans which could lead them into further conflict over land disputes.