In the United States v. Morrison case of 1915, the Supreme Court ruled on a matter concerning federal jurisdiction over crimes committed on Native American reservations. The defendant, Charles Morrison, was convicted in federal court for assault and battery against another non-Native individual within an Indian reservation in South Dakota. On appeal to the Supreme Court, Morrison argued that his conviction should be overturned because he believed that only state courts had jurisdiction over crimes between non-Natives occurring on tribal lands. The Supreme Court disagreed with this argument and upheld his conviction. They reasoned that while tribes have sovereignty rights within their territories, Congress has plenary power (complete control) over these areas due to its constitutional authority to regulate commerce with Native American tribes. Therefore, they concluded that federal law enforcement could prosecute such cases under the Major Crimes Act of 1885 which grants them jurisdiction over certain serious offenses committed by or against Indians within reservations regardless of whether those involved are members of a tribe or not.

The dissenting opinion in the United States v. Morrison case argued that Congress had the authority to regulate non-economic, violent criminal conduct based on its power under the Commerce Clause of the Constitution. The dissenters believed that gender-motivated crimes of violence have a substantial effect on interstate commerce and therefore fall within Congress's regulatory jurisdiction. They contended that such crimes not only impose substantial medical and other costs but also deter potential victims from traveling interstate, engaging in employment in certain industries, or transacting with certain kinds of businesses. Furthermore, they pointed out that existing state laws were insufficient to address this problem effectively due to biases and prejudices at local levels. Hence, federal intervention was necessary according to them.