In the case of State of South Dakota v. Collins (1918), the U.S Supreme Court was asked to determine whether a state law that prohibited non-residents from hunting game birds for commercial purposes violated the Commerce Clause of the Constitution. The defendant, Collins, was a resident of Minnesota who had been arrested in South Dakota while attempting to transport game birds he had killed out-of-state. He argued that his actions were protected by interstate commerce laws and thus beyond state regulation. The court ruled against Collins, upholding South Dakota's right to regulate hunting within its borders as part of its police powers. It found no violation with respect to interstate commerce since states have an interest in preserving their wildlife resources and can restrict or prohibit activities such as hunting if they threaten these resources' sustainability. This decision affirmed states' rights over natural resource management within their territories even when it intersects with potential commercial interests across state lines.

In the dissenting opinion for State of South Dakota v. Collins, the justice argued that the state did not have jurisdiction over a crime committed on an Indian reservation by a non-Indian against another non-Indian. The justice believed that Congress had exclusive authority to regulate and govern such matters under its plenary power over Native American tribes, as established in previous Supreme Court decisions. He contended that allowing states to exercise jurisdiction in these cases would undermine federal sovereignty and disrupt tribal self-governance. Furthermore, he expressed concern about potential conflicts between state and federal law enforcement authorities if both were allowed to operate within reservations simultaneously. Thus, he disagreed with the majority's decision upholding South Dakota's prosecution of Collins for assault occurring on an Indian reservation.