Previous decisions of the US Supreme Court held that the Nonintercourse Act did not restrict the alienability of Pueblo peoples or lands.

Justice Miller of the Supreme Court had previously ruled, "Every person who makes a settlement on any lands belonging, secured, or granted by treaty with the United States to any Indian tribe, or surveys or attempts to survey said lands, or to designate any of the boundaries by marking trees or otherwise, is liable to a penalty of $1,000.

"[3] Congress responded in 1924 and 1933 with compromise legislation to extinguish some aboriginal title and to establish procedures for determination and compensation.

The case involved the sale of alcohol by a non-Indian, Felipe Sandoval, to the Pueblo of New Mexico at the San Juan Village.

The Court held that the enabling act applied generally applicable federal Indian statutes to the Pueblo.

Sandoval repudiated the prior Supreme Court case of United States v. Joseph (1876), which had held that the Pueblos were not "Indians.

The federal government, which viewed the Pueblo title as held by tribes rather than individual Indians, argued that the Nonintercourse Act applied.