United States v. Joseph was a United States Supreme Court case that dealt with the issue of whether a Native American could be convicted of a crime in a federal court. The case involved a Native American man, Joseph, who was accused of murdering another Native American on a reservation in Arizona. The federal government argued that Joseph should be tried in a federal court, as the crime was committed on federal land. Joseph argued that he should be tried in a tribal court, as he was a Native American and the crime was committed on tribal land. The Supreme Court ultimately ruled in favor of the federal government, holding that Native Americans could be tried in federal courts for crimes committed on tribal land. The Court reasoned that Native Americans were subject to the laws of the United States, and that the federal government had the authority to prosecute crimes committed on tribal land. The Court also noted that Native Americans had the right to a fair trial, and that the federal court system was better equipped to provide such a trial than the tribal court system.

In United States v. Joseph, the Supreme Court was asked to decide whether a Native American who had been convicted of murder in an Indian Territory court could be tried again for the same crime in a federal district court. The majority opinion held that he could not, as it would violate his right against double jeopardy under the Fifth Amendment. Justice Field dissented from this decision and argued that since Congress had exclusive authority over Indian affairs, they should have been allowed to try him again if they so chose. He further noted that while double jeopardy is generally prohibited by law, there are exceptions when dealing with matters of national security or public safety; thus allowing Congress to retry Joseph did not necessarily violate any constitutional rights. In conclusion, Field believed that Congress should have been given more leeway in deciding how best to handle criminal cases involving Native Americans living within their jurisdiction.