In the case of United States v. Waller et al., 1916, the Supreme Court ruled on a dispute involving land ownership in Mississippi. The defendants, Waller and others, claimed that they had purchased certain lands from Native American tribes under treaties made with them by the British Crown prior to U.S independence. However, these purchases were not recognized by subsequent U.S legislation which asserted federal control over all Indian lands. The court held that after the creation of the United States and its Constitution, only Congress could negotiate treaties or agreements for land acquisition from Native Americans; any such transactions conducted privately were invalid unless ratified by Congress itself. Therefore, it was determined that Waller's claim to ownership based on pre-independence British treaties was void as it conflicted with later established US law asserting exclusive Congressional authority over such matters.

The dissenting opinion in the United States v. Waller et al., 1916, argued that the majority's decision to uphold a conviction for conspiracy to defraud was incorrect due to insufficient evidence. The dissent contended that there was no proof of an agreement between the defendants and any other parties involved in alleged fraudulent activities, which is essential for establishing a conspiracy charge. Furthermore, it pointed out inconsistencies and contradictions within testimonies used against the defendants during trial proceedings. It also emphasized that mere knowledge or approval of illegal actions does not constitute participation in a criminal conspiracy unless there is clear evidence of intent and active involvement. Therefore, according to this view, without concrete proof demonstrating such elements beyond reasonable doubt, upholding convictions based on circumstantial implications would be unjustified and contrary to principles of fair justice.