In Heckman v. United States (1911), the U.S. Supreme Court ruled in favor of the federal government, affirming its right to act as a trustee for Native American tribes and protect their interests against state laws that might infringe upon tribal rights or property. The case involved lands allotted to members of the Choctaw and Chickasaw Tribes under an 1898 agreement with Congress which were later sold without approval from the Secretary of Interior, violating federal law. The purchasers argued that they had acquired valid titles because Oklahoma's statute of limitations barred any challenge after five years. However, Justice Oliver Wendell Holmes Jr., writing for a unanimous court, held that state statutes could not limit the power conferred by Congress on Federal courts to enforce trust obligations owed by individuals to Indian tribes.

In the dissenting opinion for Heckman v. United States, it was argued that the federal government did not have jurisdiction over lands allotted to individual Native Americans under treaties and laws passed by Congress. The dissenting justices believed that once these allotments were made, they became private property and thus fell outside of federal control. They also disagreed with the majority's interpretation of previous court decisions regarding tribal sovereignty and land rights, arguing that those cases did not establish a broad principle giving the U.S. government authority over all matters related to Native American lands. Furthermore, they contended that allowing such extensive federal power would undermine state sovereignty and violate principles of constitutional law.