The case of Heirs of Samuel Garland, Deceased v. Choctaw Nation in 1926 revolved around a dispute over land allotment rights under the Treaty of Dancing Rabbit Creek between the U.S. government and the Choctaw Nation. The heirs of Samuel Garland, who was a half-blood Choctaw Indian, claimed that they were entitled to certain lands within the territory due to their ancestor's status as an original enrollee on tribal rolls. However, these claims were contested by both other potential heirs and members of the tribe itself. The Supreme Court ruled against Garland's descendants stating that while he was indeed listed as an original enrollee with full blood status according to tribal records; this did not automatically entitle his descendants to inherit his land allotments without clear evidence proving their lineage or demonstrating they met necessary qualifications for inheritance under relevant laws at that time. This ruling underscored how complex issues surrounding Native American treaty rights and inheritance can be when dealing with federal law versus tribal customs or traditions.

In the dissenting opinion for Heirs of Samuel Garland, Deceased v. Choctaw Nation, it was argued that the majority's decision to deny compensation to the heirs of Samuel Garland from the Choctaw Nation was incorrect. The dissenting justices believed that there were valid grounds for a claim against the tribe based on an 1830 treaty between them and United States government. They contended that under this treaty, Mr. Garland should have been recognized as a member of the tribe due to his marriage with a Choctaw woman and thus entitled to certain benefits including land allotments which he never received during his lifetime. This entitlement they argue should extend posthumously to his descendants who are now seeking redress in court over what they believe is rightfully theirs by virtue of their ancestor’s unrecognized tribal membership status.