In the case of Brewer-Elliott Oil & Gas Company et al. v. United States et al., 1922, the U.S Supreme Court was tasked with determining whether a contract for oil and gas leases on Osage Indian lands in Oklahoma violated federal law. The plaintiffs argued that they had been unfairly excluded from bidding on these leases due to collusion between certain bidders and government officials, which resulted in artificially low prices being accepted by the government. However, the court ruled against them stating that there was no evidence of fraud or collusion affecting lease sales; rather it found that all procedures were followed correctly under existing laws at that time regarding such transactions involving Native American lands held in trust by Federal Government. Furthermore, it stated any changes to this process would need to come through legislative action rather than judicial intervention.

In the dissenting opinion for Brewer-Elliott Oil & Gas Company et al. v. United States et al., Justice McReynolds expressed his disagreement with the majority's decision to uphold a lower court ruling that allowed the U.S government to cancel oil and gas leases granted by Osage Indians under an Act of Congress in 1906. He argued that this interpretation was inconsistent with previous decisions, which had upheld similar leases as valid contracts between private parties and tribal entities, protected by federal law from unilateral cancellation without due process or just compensation. Furthermore, he contended that such a broad power of revocation would undermine confidence in these types of agreements and discourage investment in Indian lands, contrary to Congressional intent behind laws promoting their economic development. Finally, he criticized the majority for failing to adequately consider evidence suggesting that lessees had acted in good faith when entering into these arrangements based on reasonable expectations about their legal validity.