In the case of Davis, Agent v. Henderson in 1924, the United States Supreme Court ruled on a dispute involving land allotment rights for Native Americans under the Dawes Act of 1887. The plaintiff was an agent representing the U.S government and argued that Henderson had unlawfully obtained possession of allotted lands from Native American owners through fraudulent means. The defendant, Henderson, claimed he legally purchased these lands after they were declared surplus by Congress in 1906 and sold to non-Native settlers. However, it was found that some sales occurred before this declaration took place which violated federal law prohibiting such transactions without explicit congressional approval. The court held that any sale or transfer made prior to Congressional authorization is voidable at suit of United States regardless if subsequent purchaser acted in good faith or not; thus ruling against Henderson's claim over those specific parcels bought prematurely. This decision reinforced protections for Native American property rights during a time when their traditional territories were being drastically reduced due to westward expansion.

In the dissenting opinion for Davis, Agent v. Henderson, Justice McReynolds disagreed with the majority's decision to uphold a lower court ruling that allowed an Indian tribe member to sell inherited land without federal approval. He argued that this interpretation of the law would lead to exploitation and loss of property for Native Americans as it disregards safeguards put in place by Congress. According to him, these protections were designed specifically because many tribal members lacked understanding about land transactions and their implications due to cultural differences or lack of education. The justice believed that ignoring such protective measures could result in significant harm and injustice towards Native American communities.