In the case of Kinney-Coastal Oil Company et al. v. Kieffer et al., 1927, the U.S Supreme Court was tasked with determining whether a state could impose taxes on oil and gas extracted from land owned by Native Americans but leased to non-Native American companies for extraction purposes. The court ruled that such taxation was not permissible under federal law because it interfered with tribal self-governance and infringed upon their rights as sovereign entities. This ruling upheld previous decisions which recognized Native American tribes' unique status within the United States legal framework, affirming their right to control resources found on their lands without interference from state governments.

The dissenting opinion in the case of Kinney-Coastal Oil Company et al. v. Kieffer et al., 1927, argued that the majority's decision was inconsistent with previous rulings and principles established by the court regarding oil leases on public lands. The dissent contended that an oil lease is a contract for sale of land, not merely a license to explore or extract resources from it; therefore, any disputes arising from such contracts should be governed by state law rather than federal law as determined by the majority ruling. Furthermore, they disagreed with the interpretation of Congressional intent behind relevant legislation regulating these leases and believed that Congress did not intend to create exclusive federal jurisdiction over all controversies involving them. They also expressed concern about potential implications for states' rights and sovereignty due to this shift towards increased federal control over local matters.