In the United States v. Carter case of 1913, the Supreme Court ruled on a dispute involving land ownership and mining rights in Alaska. The defendant, Carter, had been granted permission by an Alaskan native tribe to mine for gold on their tribal lands. However, this was challenged by the U.S government who argued that only Congress could grant such permissions under the 1867 Treaty with Russia which stated that all unoccupied or unsold lands were public property. The court sided with the government stating that while indigenous tribes have certain rights over their ancestral lands, they do not possess absolute title to these territories as per international law principles recognized by American jurisprudence. Therefore, any agreements made between private citizens and native tribes regarding land use are subject to federal laws and regulations. This decision reinforced federal authority over natural resources in Alaska's public domain despite claims from local indigenous communities about traditional usage rights.

In the dissenting opinion for United States v. Carter, Justice Holmes disagreed with the majority's interpretation of the Sherman Act and its application to labor unions. He argued that a strike by union members did not constitute an illegal restraint of trade under federal law because it was not intended to monopolize or control commerce but rather to improve working conditions and wages. Furthermore, he contended that Congress had never intended for such laws to be applied in this manner against workers seeking better terms from their employers. In his view, applying antitrust legislation in this way would unjustly criminalize legitimate labor activities and infringe upon workers' rights to organize collectively for mutual benefit.