In United States v. Murphy, the Supreme Court ruled that a treaty between the United States and an Indian tribe was not enforceable in court because it had not been ratified by Congress. The case involved a dispute over land rights between two members of the Pawnee Tribe who lived on reservation lands in Nebraska Territory. One member, Murphy, claimed he owned certain tracts of land within the reservation boundaries while another member, White Horse, argued that they belonged to him under tribal law. The U.S., as guardian of Indian tribes' interests at this time period, sought to settle their dispute through arbitration based on a treaty with the Pawnee Nation which provided for such resolution; however, since Congress had never ratified this particular treaty it could not be enforced in court and thus did not resolve their disagreement over ownership rights to these parcels of land within the reservation boundary lines. Ultimately then Supreme Court held that treaties must be approved by Congress before they can be legally binding or enforced in any way whatsoever - even if both parties agree upon its terms beforehand - thereby affirming Congressional authority over all matters concerning Native American tribes living within U.S borders

In United States v. Murphy, the Supreme Court was tasked with determining whether a criminal conviction in an Indian tribal court could be used to support a subsequent prosecution for the same offense in federal court. The majority of justices held that such double jeopardy did not exist and that the defendant could be tried twice for the same crime. Justice Field dissented from this opinion, arguing that it violated fundamental principles of justice by allowing multiple prosecutions for one offense and punishing someone more than once for their actions. He argued further that Congress had no authority to pass laws which allowed such double jeopardy as it would violate constitutional protections against cruel and unusual punishment. Furthermore, he noted that if Congress were given this power then there would be nothing preventing them from passing similar laws which applied to non-Indians as well, thus creating unequal treatment under law based on race or ethnicity alone.