In the case of Oregon v. Hitchcock in 1905, the U.S Supreme Court ruled on a dispute between the state of Oregon and Ethan A. Hitchcock, then Secretary of Interior. The conflict arose over public lands within Oregon that were initially reserved for Indian tribes but later declared as surplus by an act of Congress in 1887 (the Dawes Act). The State argued it was entitled to these lands under its enabling act which granted every alternate section of public land for support of common schools. However, the court held that this grant did not extend to lands specifically reserved for any purpose prior to its admission into Union - including those set aside for Native American reservations. Therefore, when such reservation ceased to exist or diminished in size due to federal policy changes like Dawes Act, they didn't automatically fall under state's claim but remained part of national domain unless explicitly transferred by Congress.

In the dissenting opinion for Oregon v. Hitchcock, Justice Harlan argued that the majority's decision was a departure from established principles of statutory interpretation and respect for Native American rights. He contended that when Congress passed legislation in 1855 to establish a reservation for the Klamath Indians, it intended to permanently set aside this land for their use and benefit. The subsequent act in 1864 did not explicitly revoke this reservation status but merely allowed non-Indians to settle on portions of these lands if they were unoccupied by tribal members. Therefore, according to Harlan, any ambiguity should be resolved in favor of preserving Indian rights rather than diminishing them as per longstanding legal precedents. Furthermore, he criticized the majority's reliance on administrative interpretations which contradicted Congressional intent and violated treaty obligations with indigenous tribes.