In the case of Chippewa Indians of Minnesota v. United States (1938), the Supreme Court ruled in favor of the Chippewa Indians, affirming their right to compensation for land ceded to the U.S government under an 1889 agreement. The court held that while Congress had intended to pay a fair price for these lands, it failed to do so due its reliance on inaccurate and incomplete appraisals. As such, this constituted a breach of fiduciary duty by the federal government towards Native American tribes whose interests they were supposed to protect. Therefore, it was determined that additional payment was owed by the U.S Government as just compensation for taking tribal lands at less than their true value.

In the dissenting opinion for Chippewa Indians of Minnesota v. United States, Justice McReynolds argued that the majority's decision was inconsistent with previous rulings and interpretations of treaties between Native American tribes and the U.S. government. He contended that under these treaties, lands were not simply "ceded" to the government but sold at a price agreed upon by both parties. Therefore, he believed it was wrong to deny compensation to the Chippewa tribe for timber harvested from their land by non-tribal members without their consent or payment. He also disagreed with how damages were calculated in this case as they did not take into account any increase in value over time due to inflation or other factors which would have significantly increased compensation owed to them.