In the case of State of Minnesota v. Lane, Secretary of the Interior et al., 1917, the Supreme Court was asked to determine whether or not a state had jurisdiction over land that was purchased by and held in trust for Native American tribes by the federal government. The State of Minnesota argued that it should have jurisdiction because it retained sovereignty over all lands within its borders unless explicitly ceded to another entity. However, the court ruled against Minnesota stating that when Congress purchases land for use as reservations for Native Americans, those lands become "Indian country" and are subject only to federal law - not state law. This decision reaffirmed tribal sovereignty rights and clarified how they interact with state laws.

In the dissenting opinion for the case of State of Minnesota v. Lane, Secretary of the Interior, et al., Justice Holmes argued that while he agreed with most parts of the majority's decision, he disagreed on one key point: whether or not Congress had authority to regulate and control navigable waters within a state. He believed that this power was reserved exclusively for states under their inherent sovereignty and could not be usurped by federal legislation unless explicitly granted by constitutional provision. This disagreement stemmed from his interpretation of previous court decisions which held that states retained all powers not expressly delegated to Congress in matters concerning internal improvements such as navigation regulation. Thus, according to him, even though Lake Superior is considered a navigable waterway used in interstate commerce - thus falling under federal jurisdiction - its management should still remain primarily within Minnesota’s purview because it lies entirely within its boundaries.