In the 1896 case of Carter v. Ruddy, the United States Supreme Court addressed a dispute over land ownership in Oklahoma. The plaintiff, Carter, claimed that he had purchased a plot of land from an individual who was part Choctaw Indian and therefore entitled to allotment under federal law. However, this claim was disputed by Ruddy who argued that the original owner did not have legal title to sell because his rights were restricted due to his Native American heritage. The court ruled in favor of Ruddy stating that at the time when Carter bought it, there were restrictions on alienation which meant that any sale or transfer without government approval would be voided as per existing laws pertaining to Native American lands.

The dissenting opinion in the case of Carter v. Ruddy argued that the majority's decision to uphold a tax on an inheritance was unconstitutional. The dissenters believed that this type of tax was not within the power granted to Congress by the Constitution, as it did not fall under any of its enumerated powers such as taxing imports or income. They also contended that it violated principles of federalism because it intruded upon state authority over property and inheritance laws. Furthermore, they maintained that this kind of direct taxation without apportionment among states contradicted explicit constitutional prohibitions against such practices. Thus, according to them, allowing for an unapportioned federal estate tax would set a dangerous precedent and undermine important constitutional safeguards.