Bates v. Clark
In Bates v. Clark, 95 U.S. 204, 205, 24 L.Ed. 471 (1877), the issue was whether goods seized by American military officers after finding that the owner intended to import liquor into Indian country for trade purposes, were properly seized inside of Indian country.
While the Court used broad language respecting the applicability of the Act, it was only interpreting provisions relating to penalties for importation of alcohol, by that time contained in section 20 of the 1834 Act, and further amended by statute in 1864.
While admittedly, the statements made in both American Fur and Bates suggested that all the provisions of the Acts, including the Nonintercourse statute, were limited in operation to Indian country, the Court in those cases was concerned with particular provisions of the Acts and suggested only that the trade and intercourse provisions were generally limited to Indian country.