In Johnson and Graham's Lessee v. William M'Intosh, the Supreme Court of the United States ruled that Native American tribes could not sell land to private citizens without approval from the federal government. The case involved a dispute between two individuals over ownership of certain lands in Illinois which had been sold by an Indian tribe to one individual but then purchased by another individual who claimed he had acquired it through a valid purchase from another member of the same tribe. The court held that since Native Americans were considered “domestic dependent nations” under U.S law, they did not have authority to transfer title or possession of their lands without permission from Congress or other authorized representatives of the federal government. This ruling established precedent for future cases involving tribal sovereignty and property rights, as well as set forth guidelines for how such disputes should be handled going forward.

In Johnson and Graham's Lessee v. William M'Intosh, the Supreme Court was tasked with determining whether a Native American tribe had the right to sell land to private individuals or if such transactions were invalid because they violated federal law. Justice Story wrote a dissenting opinion in which he argued that Native Americans did not have any legal authority over their lands and thus could not transfer title of those lands through sale or other means. He further stated that it would be unjust for non-Native Americans who purchased land from tribes to lose their property rights due to an act of Congress which was passed after they made the purchase. Story concluded by stating that although Congress has power over Indian affairs, it should exercise its powers in ways consistent with justice and equity towards all parties involved in these transactions.