In the 1901 case of Tucker v. Alexandroff, the U.S. Supreme Court ruled on a dispute involving maritime law and salvage rights. The plaintiff, Captain Tucker, had rescued a ship (the "Herman") that was stranded in Alaskan waters without its crew. After towing it to port, he claimed salvage rights over the vessel and its cargo under international maritime law which allows those who rescue abandoned sea vessels to claim compensation or ownership as a reward for their efforts. However, Mr. Alexandroff - who represented Russian owners of the Herman - contested this claim arguing that since Alaska was not officially recognized as American territory at that time (1897), U.S courts did not have jurisdiction over this matter. The Supreme Court disagreed with Alexandroff's argument ruling in favor of Captain Tucker stating that although Alaska might not have been fully incorporated into United States at that time; it still fell within U.S jurisdiction because Congress had established civil government there by passing an Organic Act for Alaska in 1884 thereby extending judicial laws including admiralty/maritime laws applicable to rest of USA onto Alaskan territory too.

In the dissenting opinion for Tucker v. Alexandroff, it was argued that the majority's decision to uphold a lower court ruling denying citizenship to a Russian immigrant who had lived in Alaska before its purchase by the United States was incorrect. The dissenter believed that when Congress passed legislation extending U.S. laws over Alaska, this should have included naturalization laws which would allow residents of newly acquired territories to become citizens if they so desired. They also pointed out inconsistencies between this case and previous rulings where inhabitants of annexed territories were granted citizenship rights immediately upon acquisition by the U.S., such as with Louisiana and Florida. Therefore, they concluded that Alexandroff should be considered an American citizen due to his residence in Alaska at the time of its purchase by America.