In United States v. Yorba, the Supreme Court of the United States held that a defendant could not be convicted for an offense committed on Indian land unless it was specifically prohibited by Congress. The case arose when Francisco Yorba was arrested and charged with selling liquor to Indians in violation of California law. At trial, he argued that since his actions occurred on Indian land, they were beyond the jurisdiction of state laws and thus he should be acquitted. The court agreed with this argument and found him not guilty because there had been no Congressional legislation prohibiting such activities at the time of his arrest. This decision established a precedent whereby criminal offenses occurring within Native American territories must have specific Congressional authorization before any conviction can take place.

In United States v. Yorba, the Supreme Court was asked to decide whether a Mexican land grant made by the Mexican government prior to California becoming part of the United States should be recognized as valid in U.S. courts. The majority opinion held that it should not, arguing that when Mexico ceded California to the U.S., all former laws and grants were nullified and replaced with those of the new nation's sovereign power - namely, Congress' authority over public lands granted by its own acts or treaties with foreign nations since 1848 (the date of California's admission into statehood). Justice Field dissented from this ruling on two grounds: firstly, he argued that under international law such grants could not be invalidated without compensation; secondly, he argued that even if they could be invalidated without compensation then Congress had no right to do so because it would amount to an unconstitutional taking of private property for public use without just compensation as required by Amendment V of the Constitution. He concluded his dissent stating "I cannot assent...to a decision which thus disregards both justice and constitutional principle."