In the case of United States v. Noble, 1914, the Supreme Court dealt with a dispute over land ownership in Oklahoma. The defendant, Noble, claimed that he had purchased land from an individual who was part Native American and therefore exempt from certain restrictions on selling their allotted lands under federal law. However, the government argued that this exemption did not apply because the seller was only one-eighth Native American and thus his allotment could not be sold without approval by Secretary of Interior as per Curtis Act (1898). The court ruled in favor of the government stating that even though there were some ambiguities in interpreting these laws regarding Indian allotments; they should be interpreted to protect interests of Indians against improvident sales or contracts involving their lands. Therefore it held that sale made by such individuals without governmental approval would be invalid.

In the dissenting opinion for United States v. Noble, Justice Holmes disagreed with the majority's decision to uphold a conviction based on evidence obtained through an allegedly illegal search and seizure. He argued that the Fourth Amendment protects against unreasonable searches and seizures, regardless of whether or not they yield incriminating evidence. He further contended that allowing such evidence to be used in court would undermine this constitutional protection by incentivizing law enforcement officers to conduct unlawful searches in hopes of finding useful information. In his view, excluding illegally obtained evidence from trial is necessary to deter police misconduct and preserve citizens' rights under the Fourth Amendment.