In the United States Supreme Court case of The United States v. John W. Low et al., the issue was whether or not a certain piece of land in Michigan, known as "The Half-Breed Tract," belonged to the federal government or to private individuals who had purchased it from Native Americans. The court found that although Congress had passed an act granting title to this tract of land, it did not have authority under the Constitution to do so because it would be taking property without due process and compensation for those already possessing rights in said lands. Furthermore, since no treaty existed between the U.S and any Indian tribe which ceded title over this particular tract, there was no legal basis for Congress' action either way; thus leaving ownership with those who held prior possession rights at common law - namely, those who bought from Native American tribes before passage of Congressional Act in question here. As such, judgment was rendered against appellants (the US) and appellees (Low et al.) were declared rightful owners by virtue of their pre-existing purchase agreements with Indians on whose behalf they acted as agents when purchasing said lands

In United States v. John W. Low et al., the Supreme Court was asked to decide whether a federal statute, which authorized the President of the United States to appoint an agent for Indian affairs in Oregon Territory, was constitutional. The majority opinion held that it was not and struck down the law as unconstitutional because Congress had no authority under Article I of the Constitution to pass such a law without first obtaining consent from two-thirds of both houses or by treaty with foreign nations. However, Justice McLean dissented from this decision and argued that Congress did have power under Article III Section 2 Clause 3 (the “Indian Commerce Clause”) to regulate commerce with Indian tribes and thus could pass laws related thereto without requiring approval from two-thirds of both houses or through treaties with foreign nations. He further noted that while there may be some limits on Congressional power over Indians due to their status as sovereigns within certain territories, those limits were not relevant here since this case involved only domestic relations between citizens and noncitizens living within U.S.-controlled territory