In the United States v. Quiver case of 1915, the Supreme Court ruled that federal law did not have jurisdiction over a crime committed by an American Indian against another on a reservation. The defendant, Quiver, was charged with adultery under federal law for engaging in sexual relations with a married woman who was also an American Indian living on the same reservation. However, he argued that this matter should be handled within their tribal legal system rather than through U.S. courts. The Supreme Court agreed and dismissed his indictment based on two main points: first, Congress had not explicitly extended such laws to reservations; secondly, it recognized tribes as distinct political entities capable of managing their internal affairs including criminal justice matters unless otherwise specified by Congress.

The Supreme Court case United States v. Quiver did not have a dissenting opinion recorded. The unanimous decision, written by Justice Joseph McKenna, held that the federal government had jurisdiction over crimes committed on Indian reservations even if both parties involved were Native American.