In Hatahley et al. v. United States, the Supreme Court ruled in favor of Navajo plaintiffs who had sued the federal government for damages after their horses and donkeys were seized and sold by Bureau of Indian Affairs (BIA) officials without due process or just compensation. The BIA justified its actions by claiming that the animals were grazing on public lands illegally, but this was disputed by the Navajos who argued they had a right to graze there under longstanding agreements with the U.S. Government. The court found that while individual BIA agents could not be held liable for carrying out official duties, even if those duties resulted in harm to individuals, it did hold that such immunity did not extend to wrongful acts committed outside their authority or jurisdiction - as was determined here where no proper notice or opportunity for hearing was given before seizure of property occurred.

In the dissenting opinion for Hatahley et al. v. United States, Justice Reed argued that the majority's decision to award damages to Navajo horse and burro owners was incorrect because it failed to consider whether these animals were lawfully on public lands in Utah at all. He pointed out that under federal law, unbranded livestock roaming freely on public lands are considered wild and unowned; therefore, they could be removed without compensation by government agents acting within their authority. Furthermore, he contended that even if some of these animals were branded or marked as owned by the plaintiffs, there was no evidence presented showing how many belonged to them specifically or what their value might have been. Thus, according to Justice Reed's dissenting view, the Court should not have awarded any damages without clear proof of ownership and value for each animal claimed.