The high inclination of the Uranus system to its orbit around the Sun has been known since the satellites were discovered. Lassell 1851 shows Ariel and Umbriel moving at least as far north and south of the planet as they do east and west of it. William Herschel probably noticed the same thing about Titania and Oberon in 1787.
When Uranus is at an equinox, its equator appears edge-on to the Sun, making good opportunities to observe the planet's oblateness from Earth. Mädler 1842 and Young 1883 measured significant polar flattening. It took longer to determine that the equator was within 1° of the four largest satellites' orbital planes; Barnard 1896 thought the satellite orbits might be inclined 20°-30° to the equator. It took longer to determine that the equator was within 1° of the four largest satellites' orbital planes.