In the 1896 case of Sandy White v. United States, Sandy White was convicted for murder in Indian Territory and sentenced to death. The Supreme Court had to decide whether a non-Indian could be tried under federal law for a crime committed against another non-Indian on tribal land. The court ruled that while tribes have jurisdiction over their own members, they do not have exclusive jurisdiction over all crimes occurring within their territory - particularly when those crimes involve individuals who are not tribe members. Therefore, it upheld the conviction and sentence of Mr. White by ruling that he could indeed be prosecuted under federal law despite committing his crime on tribal land.

The dissenting opinion in the case of Sandy White v. United States argued that the majority's decision to uphold White's conviction was flawed due to issues with how evidence was presented during his trial. The dissent contended that certain pieces of evidence, specifically those related to prior convictions and bad character, were improperly admitted by the lower court and prejudiced the jury against White. This bias undermined his right to a fair trial as guaranteed by the Constitution. Furthermore, they disagreed with how instructions were given to jurors about reasonable doubt standards which could have led them towards a guilty verdict more easily than if proper instruction had been provided. Therefore, it was their belief that these errors warranted reversal of White’s conviction.