In the 1906 case United States v. Keatley, the US Supreme Court ruled on a dispute over land ownership in Oklahoma. The defendant, Keatley, claimed that he had purchased the land from an individual who had received it as part of an allotment under a federal statute providing for distribution of lands to members of certain Indian tribes. However, the government argued that this sale was invalid because it violated another federal law prohibiting such sales without approval from the Secretary of Interior. The court sided with the government and held that any transfer or conveyance made by an allottee before receiving patent (title) to their allotted lands is null and void if done without consent from Secretary of Interior - even if said transfer occurred after expiration date set by Congress for restrictions against alienation (sale). This decision reinforced governmental control over Native American property rights during this period.

The dissenting opinion in the United States v. Keatley case argued that the majority's ruling was inconsistent with previous decisions of the court and violated principles of international law. The dissent contended that a person could not be tried for an act committed outside U.S territory unless it was explicitly stated by Congress, which wasn't done in this case. They also pointed out inconsistencies between this decision and prior rulings where acts committed on foreign vessels were considered under jurisdiction of their respective countries, not U.S law. Furthermore, they believed that applying domestic laws to foreigners who commit crimes abroad would lead to conflicts with other nations' sovereignty rights and potentially result in diplomatic issues or retaliation against American citizens overseas.