In the 1903 case of Sloan v. United States, the Supreme Court ruled on a matter involving land rights under Native American treaties. The plaintiff, Sloan, claimed ownership of certain lands in Washington state based on an 1855 treaty between the U.S. and Yakima Nation. However, these lands were part of a larger parcel that had been allotted to another individual by an act of Congress in 1894. The court held that while treaties with Native American tribes are equivalent to federal law and cannot be unilaterally abrogated by states or private parties, they can be superseded by subsequent acts of Congress if clear intent is demonstrated - which was found to be true in this instance with the allotment act overriding provisions from earlier treaties regarding land distribution among tribal members.

In the dissenting opinion for Sloan v. United States, Justice Brewer argued that the majority's decision was a misinterpretation of the Sherman Anti-Trust Act. He believed that this law was not intended to regulate commerce within individual states but rather to prevent monopolies and restraints on trade between different states. In his view, since Sloan's business operations were confined entirely within Texas, they did not constitute interstate commerce and thus should not be subject to federal regulation under the Sherman Act. Furthermore, he contended that if Congress had intended for such broad interpretation of its powers over commerce as suggested by the majority ruling in this case, it would have explicitly stated so in its legislation.