In the United States v. Sweeny case of 1894, the Supreme Court dealt with a dispute over land ownership in New Mexico. The plaintiff, John Sweeny, claimed that he had purchased lands from Pueblo Indians who were living on it at the time and therefore held rightful title to them. However, these sales were not approved by Congress as required by law for transactions involving Indian lands. The government argued that since there was no Congressional approval for these sales, they were invalid and thus Mr.Sweeny did not have legal claim to this property. The court ruled in favor of the U.S Government stating that under existing laws and treaties between Native American tribes and the federal government - specifically Article 12 of Treaty made with Navajo Indians on June 1st ,1868- any sale or lease of tribal lands must be approved by Congress before it can become legally binding; without such approval any transaction is considered null & void. This decision reaffirmed previous rulings which established Federal supremacy over state laws regarding dealings with indigenous peoples' territories thereby protecting their rights against exploitation.

In the dissenting opinion for United States v. Sweeny, Justice Brewer argued that the majority's decision to uphold a tax on distilled spirits was incorrect. He believed that this tax constituted an unlawful seizure of property without due process of law, violating the Fifth Amendment rights of distillers. According to him, while Congress has broad powers to levy taxes and regulate commerce, it cannot do so in a way that infringes upon individual constitutional rights. The government's power to collect taxes does not supersede its obligation to respect private property rights under the Constitution. Therefore, he disagreed with his colleagues' interpretation and application of these principles in this case.