In the case of Seymour v. Superintendent of Washington State Penitentiary, 1961, Richard Seymour, a Native American and member of the Colville Indian Tribe was convicted for burglary in Washington state court. He argued that his conviction should be overturned because as an enrolled tribal member living on a reservation, he was not subject to state jurisdiction under Public Law 280 (PL-280). PL-280 transferred federal law enforcement authority within certain areas concerning Indian affairs to six specific states including Washington. The Supreme Court ruled in favor of Seymour stating that while PL-280 did grant these states jurisdiction over crimes committed by or against Indians on reservations; it only applied to those reservations which were located entirely within one of these states' borders. Since part of the Colville Reservation extended into Idaho (a non-PL 280 state), it wasn't considered "Indian country" where Washington had full jurisdiction under PL-280 and therefore they lacked legal authority to prosecute him.

In the dissenting opinion for Seymour v. Superintendent of Washington State Penitentiary, Justice Frankfurter argued that the majority's decision to extend federal jurisdiction over crimes committed by Native Americans on their reservations was a departure from long-standing precedent and an unwarranted intrusion into state sovereignty. He contended that Congress had not intended to alter this balance when it passed the Indian Reorganization Act in 1934, as suggested by the majority. Instead, he believed that Congress sought only to encourage tribal self-government within existing legal frameworks rather than create new ones. Furthermore, he expressed concern about potential confusion and conflict arising from dual federal-state jurisdiction over such cases. In his view, maintaining clear lines between state and federal authority would better serve both justice and public order.