In the case of Lampasas v. Bell in 1900, the U.S Supreme Court ruled on a dispute involving land ownership and jurisdiction between Texas and Oklahoma. The plaintiff, Lampasas, claimed that he had purchased land from Native Americans residing in what was then considered Indian Territory (now Oklahoma). However, defendant Bell argued that this purchase was invalid as it violated federal law which prohibited such transactions without congressional approval. The court sided with Bell stating that only Congress could approve sales of tribal lands to non-Native individuals or entities. Therefore, any sale made without such approval would be deemed void and unenforceable by law. This ruling reinforced the authority of federal laws over state laws when dealing with matters related to Native American affairs.

The dissenting opinion in the case of Lampasas v. Bell argued that the majority's decision to uphold a lower court ruling, which found in favor of Bell, was incorrect due to an improper interpretation of Texas law. The dissent contended that under Texas law, it is not necessary for a plaintiff (in this case Lampasas) to prove they were unaware of fraudulent activity at the time they entered into a contract or agreement. Instead, it is sufficient if they can demonstrate their ignorance at any point during its execution. Therefore, according to this viewpoint, even if Lampasas had discovered fraud after entering into an agreement with Bell but before completing all obligations under said agreement - as was alleged - he should still have been able to bring his claim forward and potentially receive relief from the courts.