In the case of English v. Richardson, Treasurer of Tulsa County, Oklahoma in 1911, the U.S Supreme Court was tasked with determining whether a tax imposed on an Indian allotment by local authorities was lawful. The plaintiff argued that as per federal law and treaties between Native American tribes and the United States government, such lands were exempt from taxation until they had been sold or otherwise transferred to non-Indians. However, local officials contended that once land had been allotted to individual tribal members rather than held communally by tribes themselves it became taxable property under state law. The court ruled in favor of English (the plaintiff), stating that these lands remained exempt from taxation until their status changed through sale or other transfer methods recognized by federal law.

The dissenting opinion for the case English v. Richardson, Treasurer of Tulsa County, Oklahoma argued that the majority's decision was incorrect in its interpretation of the law and its application to this particular case. The dissenting justices believed that there were significant legal errors made by the majority in their ruling. They contended that a proper reading of relevant statutes would lead to a different conclusion than what was reached by the majority. Furthermore, they disagreed with how certain facts of this case were interpreted and applied within a legal context by their colleagues on the bench. This disagreement led them to conclude that justice had not been served properly in this instance due to these perceived misinterpretations and misapplications of both fact and law.