In the case of Territory v. Lockwood, the Supreme Court was tasked with determining whether a territorial court had jurisdiction to try an individual for murder committed on Indian land in Utah territory. The defendant argued that since he was not an Indian and did not commit the crime within any organized state or territory, he could only be tried by federal courts. However, the Supreme Court held that Congress had given authority to territories to exercise criminal jurisdiction over non-Indians who committed crimes on Indian lands within their boundaries. Furthermore, they found that this power extended even when no treaty existed between Indians and whites regarding such matters as it is assumed Congress intended for these powers to exist unless otherwise specified in legislation or treaties. As a result, they ruled against Lockwood and affirmed his conviction by the territorial court of Utah.

In Territory v. Lockwood, the Supreme Court of the United States was asked to decide whether a territorial statute that prohibited non-residents from engaging in certain occupations within its borders violated the privileges and immunities clause of Article IV of the Constitution. The majority opinion held that it did not violate this clause because Congress had plenary power over territories and could enact laws for their governance as long as they were consistent with constitutional principles. Justice Field dissented, arguing that while Congress has broad powers over territories, those powers are limited by constitutional guarantees such as those found in Article IV's privileges and immunities clause. He argued further that if states can pass laws restricting access to professions based on residency requirements then so too should be allowed in territories since they are subject to similar restrictions under federal law. Furthermore, he contended that any attempt by a territory to restrict access would be an unconstitutional infringement upon citizens' rights guaranteed by Article IV's privileges and immunities clause regardless of congressional approval or disapproval.