In the United States v. Sweet case of 1902, the Supreme Court ruled on a dispute involving land ownership in Oklahoma. The defendant, Sweet, was accused by the U.S government of unlawfully occupying and claiming lands that were part of an Indian reservation under federal protection. The lower court had initially decided in favor of Sweet based on his argument that he had acquired rights to these lands through a lease from tribal members who held allotments there. However, upon review by the Supreme Court it was determined that such leases violated existing laws which prohibited any transfer or leasing of allotted Indian lands without explicit approval from the President or Congress - something which hadn't been obtained in this instance. Therefore, it was concluded that Sweet's claim to these lands lacked legal basis and his occupancy constituted trespassing on federally protected property.

In the dissenting opinion for United States v. Sweet, Justice Harlan argued that the majority's decision was inconsistent with previous rulings and violated principles of federalism. He contended that it was not within the power of Congress to regulate commerce in such a way as to infringe upon state sovereignty by allowing federal courts to interfere with local law enforcement efforts. He further asserted that if Congress could authorize federal officers to arrest individuals without warrant or probable cause, then there would be no limit on its ability to encroach upon areas traditionally reserved for state authority. In his view, this case represented an unwarranted expansion of congressional power at the expense of states' rights and individual liberties.