In the case of Price v. United States and Osage Indians in 1898, the U.S Supreme Court was tasked with determining whether a land sale agreement between private citizens and Native American tribes required federal approval to be considered valid. The dispute arose when John D. Price purchased land from members of the Osage tribe without obtaining consent from Congress, as mandated by an 1834 law known as the Indian Intercourse Act which aimed at protecting indigenous peoples from exploitation. When he attempted to assert his ownership rights over this property, both the government and tribe contested it on grounds that it violated said act. The court ruled against Price stating that any purchase or grant of lands held by Native Americans must be ratified by Congress before they can take effect legally; hence making his acquisition invalid due to non-compliance with existing laws governing transactions involving tribal lands. This decision reinforced federal authority over dealings concerning native territories while underscoring their protective role towards indigenous communities against potential abuses.

In the dissenting opinion for Price v. United States and Osage Indians, Justice Harlan argued that the majority's decision was inconsistent with previous rulings regarding Indian land rights. He contended that under established law, Native American tribes held a right of occupancy to their lands which could only be extinguished by voluntary cession or through war. The government did not have an unrestricted power to dispose of these lands without tribal consent. In this case, he believed the Osage tribe had never voluntarily surrendered its title to the disputed property in Kansas; therefore, it remained rightfully theirs despite being sold by Congress to settlers like Price. Furthermore, Harlan disagreed with how his colleagues interpreted certain treaties and statutes related to this issue - he felt they were misconstrued in favor of non-Indian interests at expense of tribal ones.