In the United States v. Mitchell case of 1906, the Supreme Court had to decide whether a federal statute that made it illegal for any person to cut or cause damage to timber on lands reserved for public use applied to Native American reservations. The defendant, Mitchell, was a member of an Indian tribe who unlawfully cut down and sold timber from reservation land in Minnesota without permission from either his tribe or the U.S government. He argued that he was exempted because he is an Indian living on a reservation and therefore not subject to federal law regarding public lands. The court ruled against him stating that even though these were tribal lands held in trust by the U.S., they still fell under "lands reserved for public uses" as described in the statute since they are maintained by Congress for specific purposes including conservation efforts. Therefore, this law also applies within Indian reservations making Mitchell's actions illegal under federal law.

In the dissenting opinion for United States v. Mitchell, Justice Harlan argued that the majority's decision was a misinterpretation of Congress' intent and an overreach of judicial power. He contended that when Congress passed legislation to compensate Native Americans for their land, it intended to provide them with full ownership rights - not just monetary compensation. Therefore, he believed that any disputes regarding this matter should be settled in court rather than being decided by administrative agencies or executive officers who may have conflicts of interest or biases against Native American claims. Furthermore, he criticized the majority's reliance on previous cases which did not directly address this issue and warned about potential negative consequences such as undermining trust between Native Americans and the federal government.