In the United States v. Coe case of 1897, the Supreme Court ruled on a dispute over land ownership in Washington state. The defendant, William P. Coe, had purchased land from Native Americans who were part of an unrecognized tribe and not under federal protection or treaties at that time. However, the U.S government claimed it owned this property because it was public domain land acquired through a treaty with recognized tribes in 1855. The court held that even though these particular Native Americans weren't federally recognized as a tribe when they sold their lands to Mr.Coe (in fact they were only acknowledged later), they still didn't have legal authority to sell those lands without federal approval according to Nonintercourse Act which prohibits sales of Indian lands without Congressional consent. Therefore, Mr.Coe's purchase was deemed invalid and he lost his claim to the property since Congress never ratified this sale; thus affirming that all native tribal land transactions required congressional approval regardless if tribes are officially recognized or not by Federal Government.

In the dissenting opinion for United States v. Coe, Justice Harlan disagreed with the majority's decision to uphold a lower court ruling that allowed federal authorities to seize property without due process of law. He argued that this violated the Fourth and Fifth Amendments, which protect against unreasonable searches and seizures and guarantee due process rights respectively. Harlan contended that these constitutional protections should extend to all individuals within U.S territory regardless of their citizenship status or whether they were in an organized or unorganized territory at the time of seizure. He also criticized his colleagues' interpretation of "due process," stating it was too narrow and failed to consider broader principles such as fairness, justice, liberty, and equality under law.