In the 1913 case of Bowe v. Scott, the United States Supreme Court dealt with a dispute over land ownership in Oklahoma. The plaintiff, Bowe, claimed that he was entitled to certain lands under an agreement made with members of the Choctaw and Chickasaw tribes before Oklahoma became a state. However, these agreements were not approved by Congress as required by law at that time for transactions involving Native American tribal lands. The defendant, Scott (the Secretary of Interior), argued that because Congressional approval was never obtained for these agreements they were invalid and thus Bowe had no claim to the land. The Supreme Court ruled in favor of Scott stating that without Congressional approval any such contracts or leases are void even if they have been recognized by local authorities after statehood has been granted. This decision upheld federal laws designed to protect Native American tribes from being exploited through unfair land deals.

In the dissenting opinion for Bowe v. Scott, it was argued that the majority's decision to uphold a law prohibiting non-residents from fishing in Louisiana waters violated the Privileges and Immunities Clause of Article IV of the Constitution. The dissenting justices believed that this clause guarantees citizens of each state equal access to all privileges and immunities enjoyed by citizens in other states, including natural resources such as fish. They contended that while states have authority over their own natural resources, they cannot discriminate against out-of-state residents when granting access to these resources. Therefore, they concluded that Louisiana's law unfairly discriminated against non-residents and should be struck down as unconstitutional.