In the United States v. McCoy case of 1903, the Supreme Court ruled on a matter involving federal jurisdiction over crimes committed in Indian Territory. The defendant, McCoy, was charged with larceny under federal law for stealing cattle from an individual who resided within Indian Territory but was not himself Native American. McCoy argued that because his alleged crime took place in Indian Territory and involved non-Native individuals, it should be subject to local rather than federal laws. However, the court disagreed and upheld his conviction by asserting that Congress had exclusive legislative authority over all U.S territories including those occupied by Native Americans. Therefore any criminal acts committed there were subject to federal jurisdiction regardless of whether they involved Natives or non-Natives.

In the dissenting opinion for United States v. McCoy, the justice argued that the defendant's conviction should not have been upheld because it was based on insufficient evidence. The justice contended that there was no clear proof of intent to defraud, which is a necessary element in cases involving fraudulent use of mail services under federal law. Furthermore, he believed that mere suspicion or conjecture could not be used as a basis for establishing guilt beyond reasonable doubt and thus considered this an error by the lower court. He also criticized how certain pieces of evidence were interpreted and emphasized their potential ambiguity. Therefore, he concluded that due process had been violated and advocated for reversing the judgment against McCoy.