In the Chickasaw Nation v. United States case of 1945, the Supreme Court ruled against the Chickasaw Nation's claim for compensation from the U.S. government for lands that were taken from them and sold to non-Native settlers in violation of their treaty rights. The court held that Congress had plenary power over Indian affairs and could unilaterally alter or abrogate treaties with Native American tribes without their consent or compensation. This decision reinforced a long-standing legal doctrine known as "congressional plenary power," which holds that Congress has complete authority over all matters relating to Native Americans, including land ownership and tribal sovereignty issues.

The dissenting opinion in the case of Chickasaw Nation v. United States argued that the majority's interpretation of the statute was incorrect and did not align with congressional intent. The dissenters believed that Congress intended to exempt tribal governments from federal gambling taxes, as it does for state governments. They pointed out that treating tribes differently than states contradicts principles of Indian sovereignty and self-governance recognized by federal law and policy. Furthermore, they contended that if Congress had wanted to tax tribes on their gaming revenues, it would have done so explicitly rather than leaving it up to judicial interpretation. Therefore, they disagreed with the majority's decision to uphold these taxes against tribal entities.