In the case of Chippewa Indians of Minnesota v. United States et al., 1936, the Supreme Court was asked to determine whether certain lands in Minnesota were part of an Indian reservation or if they had been ceded to the U.S. government by a treaty signed in 1889. The Chippewa Tribe claimed that under this treaty, they retained hunting and fishing rights on these lands even though it was sold for settlement purposes. However, the U.S government argued that these rights were extinguished when the land was opened up for public sale. The court ruled against the tribe stating that while treaties with Native American tribes should be interpreted as those tribes would have understood them at signing time; there is no evidence suggesting that either party intended to reserve such rights after selling off reservation land for settlement purposes. Therefore, any hunting and fishing privileges previously enjoyed by tribal members ceased once their ancestral homelands became public domain.

In the dissenting opinion for Chippewa Indians of Minnesota v. United States, it was argued that the majority's decision failed to honor treaty obligations between the U.S. government and Native American tribes. The dissenting justices believed that these treaties should be interpreted as they would have been understood by the tribes at their signing, not through a modern lens or with an eye towards current political convenience. They contended that when Congress ratified these treaties, it accepted certain responsibilities towards Native Americans which could not simply be dismissed later on due to changes in policy or perspective. Furthermore, they asserted that if there were any ambiguities in interpreting these agreements, such uncertainties should always be resolved in favor of indigenous peoples - who often had limited understanding of European legal concepts during negotiations - rather than against them.