In United States, Lyon et al. v. Huckabee, the Supreme Court of the United States was asked to decide whether a federal statute that authorized the Secretary of the Interior to issue patents for land in the Indian Territory was constitutional. The Court held that the statute was constitutional, and that the Secretary of the Interior had the authority to issue patents for land in the Indian Territory. The case arose when the Secretary of the Interior issued a patent to the defendant, Huckabee, for a tract of land in the Indian Territory. The plaintiffs, Lyon et al., argued that the patent was invalid because the statute authorizing the Secretary of the Interior to issue patents for land in the Indian Territory was unconstitutional. The plaintiffs argued that the statute violated the Fifth Amendment of the United States Constitution, which prohibits the taking of private property for public use without just compensation. The Supreme Court rejected the plaintiffs' argument, holding that the statute was constitutional. The Court reasoned that the statute did not violate the Fifth Amendment because the land in the Indian Territory was not private property, but rather was held in trust by the United States for the benefit of the Indian tribes. The Court further held that the Secretary of the Interior had the authority to issue patents for land in the Indian Territory, and that the patent issued to the defendant was valid.

In United States, Lyon et al. v. Huckabee (1872), the Supreme Court was tasked with deciding whether a federal court had jurisdiction to hear an appeal from a decision of the Arkansas Supreme Court in which it held that certain lands were not subject to taxation by the state. The majority opinion found that such appeals could only be heard if they involved questions of federal law or constitutional issues; since this case did not involve either, it was determined that no appeal could be taken and thus affirmed the judgment of the lower court. Justice Field dissented from this ruling on two grounds: firstly, he argued that Congress had granted appellate jurisdiction over all cases arising under state laws and secondly, he maintained that even if there was no express grant of authority for such appeals then one should still exist as part of inherent judicial power vested in courts by Article III Section 2 Clause 1of Constitution. He concluded his dissent by noting “that when parties are brought into controversy respecting their rights before any tribunal whatever…they have a right to expect justice at its hands” and thus felt compelled to disagree with majority's holding denying them access to justice through an appeal process