In the case of Kiowa Tribe of Oklahoma v. Manufacturing Technologies, Inc., 1997, the U.S Supreme Court ruled that Indian tribes have sovereign immunity from lawsuits in state courts. The dispute began when Manufacturing Technologies sued the Kiowa Tribe for defaulting on a promissory note. The tribe argued they were immune from such suits due to their status as a federally recognized tribe. Initially, lower courts sided with Manufacturing Technologies but upon appeal to the Supreme Court, it was decided that tribal sovereignty protected them from these types of legal actions unless Congress specifically authorized such suits or if the tribe waived its immunity rights.

In the dissenting opinion for Kiowa Tribe of Oklahoma v. Manufacturing Technologies, Inc., Justice Stevens argued that tribal sovereign immunity should not extend to commercial activities conducted off reservation lands. He contended that such a broad interpretation of tribal immunity could potentially allow tribes to avoid obligations under contracts and other business dealings, which would be unfair to non-tribal entities engaging in commerce with them. Furthermore, he suggested this expansive view of tribal sovereignty was inconsistent with previous court rulings and federal policy aimed at promoting economic interactions between tribes and non-tribal businesses. Stevens also expressed concern about the potential negative impact on economic development if tribes were perceived as unreliable or risky business partners due to their ability to evade contractual responsibilities through claims of sovereign immunity.