In the United States v. Anderson case of 1912, the Supreme Court ruled on a dispute regarding land ownership in Alaska. The defendant, Mr. Anderson, had purchased land from an Alaskan Native American tribe and was subsequently charged by the U.S government for unlawfully acquiring public lands. The court held that under existing laws at that time (the Treaty of Cession with Russia in 1867), native tribes did not have recognized title to their traditional territories unless granted by Congress or through treaty negotiations; therefore they could not legally sell it to private individuals like Anderson. This ruling effectively meant that all unallocated lands were considered federal property until otherwise designated by law or treaty agreement.

In the dissenting opinion for United States v. Anderson, Justice Holmes argued that the defendant's conviction should not be overturned due to a technicality in jury instructions. He believed that while there may have been an error in instructing the jury on how to interpret "intent," it was not significant enough to warrant overturning a guilty verdict. The majority of justices ruled that because intent is such a crucial element in determining guilt or innocence, any misinterpretation could lead jurors astray and result in an unjust outcome. However, Justice Holmes disagreed with this interpretation and felt that even if there had been some confusion over what constituted "intent," it did not necessarily mean that the defendant would have been found innocent otherwise.