In Choate v. Trapp, the U.S. Supreme Court ruled on a case involving taxation of lands allotted to members of the Five Civilized Tribes in Oklahoma by Secretary of State Board of Equalization, Mr. Trapp. The court held that these lands were not exempt from state and local taxation after the expiration of their trust period or removal restrictions against alienation (sale). This decision was based on an interpretation of several Congressional acts related to tribal land allotments which did not explicitly provide tax exemption for such lands beyond those periods. The court reasoned that once these restrictions were lifted, there was no legal basis for continued tax immunity as it would place undue burden on other taxpayers within the state who do not enjoy similar exemptions.

The dissenting opinion in the case of Choate v. Trapp, argued that the tax imposed by Oklahoma on restricted Indian lands was unconstitutional. The justice contended that these lands were exempt from state taxation under federal law and treaties with Native American tribes. He believed this exemption to be a crucial part of the U.S government's policy towards Native Americans, aimed at protecting them from being dispossessed of their land through financial pressures such as taxes. Furthermore, he asserted that Congress had not given explicit permission for states to impose such taxes on restricted Indian lands - something he considered necessary due to the unique legal status of these territories within U.S jurisdiction.