In the case of United States v. Smull, 1914, the Supreme Court ruled on a dispute involving land ownership in Oklahoma. The defendant, Smull, had purchased land from an individual who was part Indian and part Caucasian but was not recognized as a member of any tribe. Under federal law at that time, only Native Americans who were members of recognized tribes could sell their allotted lands without government approval. The plaintiff argued that because the seller wasn't officially affiliated with any tribe when he sold his property to Smull, no government approval was needed for this transaction. However, the court disagreed with this argument and sided with the U.S Government's claim that despite his mixed heritage and lack of tribal affiliation; he still required permission from authorities before selling his allotment due to being classified as an Indian under existing laws during those times. The ruling emphasized how racial identity determined legal rights and obligations in early twentieth-century America - particularly regarding property transactions among indigenous people or between them and non-indigenous individuals.

The dissenting opinion in the United States v. Smull case argued that the majority's decision to uphold a conviction based on circumstantial evidence was flawed. The dissenters believed that there was insufficient proof to establish guilt beyond reasonable doubt, which is a fundamental principle of American criminal law. They contended that while circumstantial evidence can be used in court, it should not be the sole basis for convicting someone of a crime as serious as murder without more direct and compelling proof. Furthermore, they expressed concern about potential miscarriages of justice resulting from over-reliance on such indirect forms of evidence.