In the United States v. Michigan case of 1902, the Supreme Court ruled on a dispute over public land in Michigan that had been sold to private entities by the federal government. The state of Michigan claimed ownership of these lands based on an 1836 treaty with local Native American tribes and subsequent legislation passed by Congress granting certain lands to the state for educational purposes. However, due to clerical errors, some parcels were mistakenly sold off before they could be transferred to Michigan's control. The court held that despite these mistakes, once land was designated as part of a public sale it became irrevocable without specific congressional action - even if this contradicted previous agreements or treaties made with states or native tribes. Therefore, any sales conducted prior to formal transfer were considered valid under federal law and did not infrive upon rights granted under earlier treaties or laws.

In the dissenting opinion for United States v. Michigan, 1902, Justice Harlan disagreed with the majority's decision to dismiss the case on jurisdictional grounds. He argued that this was a matter of public rights and not merely an issue between private parties. The government had a vested interest in protecting its property from trespassers or those who would unlawfully claim it as their own - even if they were states themselves. According to him, when such disputes arise over federal land within state boundaries, it is essential for the Supreme Court to intervene and assert federal authority rather than leaving resolution up to individual states which may be biased towards their interests. Thus he believed that dismissing this case undermined both national sovereignty and property rights of U.S Government.