In the United States v. Nice case of 1915, the U.S Supreme Court ruled that Native Americans who had been granted citizenship were still subject to federal laws regarding alcohol consumption on tribal lands. The defendant, William Nice, was a member of the Omaha Tribe and had been charged with illegally introducing alcohol into an Indian reservation in violation of federal law. Despite being recognized as a citizen under an act passed by Congress in 1887 (the Dawes Act), he argued that this did not apply to him due to his status as a citizen. However, the court disagreed stating that while certain rights were conferred upon Native Americans through citizenship such as owning property or suing in court; they remained "Indians" under federal jurisdiction when it came to issues related directly to their tribes like regulation of liquor traffic among members living on reservations.

In the dissenting opinion for United States v. Nice, Justice Holmes argued that Native Americans should be subject to state laws regarding alcohol consumption because they were citizens of the United States and therefore under its jurisdiction. He believed that when Congress granted citizenship to Native Americans in 1887 through the General Allotment Act (also known as Dawes Act), it intended them to fully participate in American society, including adhering to state laws. The majority's interpretation of this act was flawed according to him; he contended that by granting citizenship without explicitly stating exemptions from certain laws created a contradiction within their ruling. Furthermore, he pointed out inconsistencies with previous rulings where tribal members were held accountable under state law despite maintaining tribal relations or living on reservations.