In the United States v. New York Indians case of 1898, the U.S Supreme Court ruled on a dispute over land rights between Native American tribes and the state of New York. The Seneca Nation claimed that they were entitled to lands under various treaties which had been violated by New York State when it purchased their lands without federal approval, as required by the Nonintercourse Act (1790). However, the court held that this act did not apply to these transactions because at its enactment in 1790, these lands were owned not by Indian tribes but by individual native Americans who sold them privately. Therefore, no federal approval was needed for such sales according to Justice Edward Douglass White's majority opinion. This decision effectively denied Seneca Nation’s claim over disputed territories.

In the dissenting opinion for United States v. New York Indians, Justice Harlan argued that the majority's decision was inconsistent with previous rulings and principles of justice. He contended that the treaty at issue should be interpreted in favor of the Native American tribes involved, as they were disadvantaged during negotiations due to language barriers and lack of legal knowledge. Furthermore, he disagreed with the majority's interpretation of "improvements" made on reservation lands - arguing it should include all changes beneficial to tribal life rather than just physical alterations or constructions. Additionally, he believed that Congress did not intend to deprive these tribes of their rights without compensation when passing relevant legislation. Therefore, according to Justice Harlan’s perspective, denying them payment for land taken by settlers was unjust.