In the United States v. Bartlett case of 1914, the Supreme Court ruled on a dispute involving land ownership in Alaska. The plaintiff, John W. Bartlett, claimed that he had purchased an island from Native Alaskans and sought to have his title recognized by U.S law. However, the government argued that under existing legislation - namely "An Act Providing for the Construction and Maintenance of Roads, etc., in Alaska," passed by Congress in 1905 - only it could purchase or own land within Alaska's territory unless explicitly stated otherwise. The court sided with the government's interpretation of this act; Justice Holmes delivered its unanimous decision stating that while there was no explicit prohibition against private purchases like Bartlett’s within this particular piece of legislation itself, other laws clearly established federal control over all Alaskan lands not specifically set aside for other purposes (such as reservations). Therefore any sale made without governmental approval would be considered invalid. This ruling reinforced federal authority over territorial lands and highlighted how such power can override individual property rights when they conflict with broader policy objectives.

In the dissenting opinion for United States v. Bartlett, it was argued that the government did not have sufficient evidence to prove its case against Bartlett. The dissenting justices believed that the circumstantial evidence presented by the prosecution was insufficient to establish guilt beyond a reasonable doubt. They pointed out inconsistencies and gaps in the prosecution's narrative, suggesting alternative explanations for some of the key facts in question. Furthermore, they criticized what they saw as an over-reliance on inference and speculation rather than concrete proof. In their view, this lack of solid evidence meant that Bartlett should be acquitted or at least granted a new trial where these issues could be more thoroughly examined.