The United States brought a case against Gordon D. Boyd and others for the alleged illegal sale of public lands in Arkansas. The defendants argued that they had purchased the land from an Indian tribe, which was authorized to sell it by treaty with the United States government. The Supreme Court held that while treaties between Indians and the federal government are valid, they do not give tribes authority to convey title to land beyond their own boundaries without express permission from Congress or other competent authority. Therefore, since no such authorization existed in this case, any purchase made by Boyd and his associates was invalid under U.S law and could not be enforced against them as legal purchasers of public lands within Arkansas territory.

In the United States v. Gordon D. Boyd and Others, the Supreme Court was tasked with determining whether a certain parcel of land in Arkansas belonged to the state or to private individuals who had purchased it from Native Americans living on it prior to its admission into the Union as a state. The majority opinion held that since Arkansas had not yet been admitted into the Union when these purchases were made, they could not be recognized by federal law and thus did not confer title upon those individuals; instead, title remained vested in Arkansas itself. However, Justice McLean dissented from this decision arguing that although Congress may have intended for all lands within newly-admitted states to become property of said states upon their admission into the Union, such an intention was never explicitly stated nor codified in any statute or other legal document; therefore he argued that recognizing these pre-statehood purchases would be consistent with principles of justice and equity given how long ago they occurred before Arkansas's admittance as a state.