In the United States v. Montana Lumber and Manufacturing Company case of 1904, the Supreme Court ruled on a dispute over land ownership in Montana. The U.S government claimed that certain lands were part of an Indian reservation under treaty provisions and thus not subject to homestead laws or sale by private entities like the defendant company. On the other hand, Montana Lumber argued it had legally acquired these lands from individuals who had obtained them through homesteading before they were designated as part of a reservation. The court sided with the government, ruling that once lands are included within an Indian reservation boundary by executive order or congressional act, they cannot be alienated without explicit authorization from Congress - regardless if such inclusion occurred after initial settlement claims under homestead laws.

The dissenting opinion in the case of United States v. Montana Lumber and Manufacturing Company argued that the government did not have a valid claim to land on which timber had been cut by the defendant company. The justice held that, under existing law, only individuals who were citizens or intended to become citizens could make claims for public lands with valuable timber resources. Since corporations cannot be considered as having citizenship status or intent to naturalize, they should not be able to stake such claims either directly or indirectly through their agents. Therefore, according to this view, any claim made by a corporation was invalid from its inception and thus could not later be validated by an act of Congress granting rights retrospectively. This would mean that at the time when Montana Lumber started logging operations on these lands there was no valid ownership claim against them; hence it cannot now be held liable for trespassing.