In the case of Harnage et al. v. Martin et al., 1916, the U.S Supreme Court dealt with a dispute over land allotments in Oklahoma that were originally assigned to members of the Choctaw and Chickasaw tribes under an agreement ratified by Congress in 1902. The plaintiffs, who were non-Indian purchasers, claimed they had acquired rights to these lands through tax sales after original allottees failed to pay taxes on them. However, defendants argued that such tax sales were invalid because federal law provided a five-year period during which these allotted lands would be exempt from taxation. The Supreme Court ruled in favor of the defendants (Martin and others), upholding their claim on grounds that Congress intended for this five-year exemption period as protection against loss of land due to unpaid taxes for tribal members not familiar with such obligations. Therefore, any sale based on failure to pay taxes within this protected timeframe was deemed void.

The dissenting opinion in the case of Harnage et al. v. Martin et al., 1916, argued that the majority's decision to uphold a lower court ruling denying certain individuals their rights to land allotments was incorrect. The dissenters believed that these individuals were entitled to such allotments under existing treaties and laws pertaining to Native American tribes, specifically those who are members of the Five Civilized Tribes in Indian Territory (now Oklahoma). They contended that Congress had intended for these laws and treaties to be liberally construed in favor of Native Americans' rights and interests, which included granting them land allotments as part of efforts towards assimilation into mainstream American society. Therefore, they felt it was unjust for the courts not only deny these claims but also refuse any further investigation into whether or not claimants met eligibility criteria set forth by law.