The U.S. Supreme Court case Heirs of Garland, Deceased v. Choctaw Nation in 1920 revolved around a dispute over land allotment within the Choctaw Nation territory. The heirs of Garland, who was an enrolled member of the Choctaw tribe, claimed that they were entitled to certain lands under treaties between the United States and the Choctaw Nation from 1830 and 1866 as well as an Act passed by Congress in 1902 concerning tribal land distribution. However, these claims were contested by other members of the tribe who argued that Garland's enrollment had been fraudulent due to his lack of Native American ancestry. The court ruled against Garland's heirs on several grounds: firstly, it found no evidence supporting their claim about his legitimate membership; secondly, it held that even if he had been a member at some point in time but later removed for fraud or mistake (which was not proven), this would not entitle him or his descendants to any benefits under those treaties or Acts; thirdly and most importantly perhaps - it emphasized how such matters should be resolved internally within tribes rather than through federal courts unless there is clear statutory authorization for judicial intervention.

In the dissenting opinion for the case Heirs of Garland, Deceased v. Choctaw Nation, it was argued that the majority's decision failed to properly interpret and apply relevant laws and treaties. The dissenting justices believed that under both U.S law and previous agreements with Native American tribes, individual members of those tribes had a right to sell their allotted lands after a certain period. They disagreed with the majority's view that these sales required approval from tribal authorities or were otherwise restricted by tribal law. In their view, this interpretation undermined federal policy aimed at encouraging economic independence among Native Americans by allowing them to freely alienate their property. Furthermore, they contended that there was no clear evidence in this particular case showing any fraud or undue influence in connection with land sale transactions involving Choctaw tribe members.