In the 1984 case of Lawrence County et al. v. Lead-Deadwood School District No. 40-1, the U.S Supreme Court ruled on a dispute over tax revenue allocation from federal mining leases in South Dakota's Black Hills region. The county had been distributing these funds to its school districts based on their respective student populations, but this was challenged by one district that argued it should receive more due to its location within the mineral-rich area where mining operations were taking place. The court held that under federal law (the Mineral Lands Leasing Act), states have discretion in allocating such revenues and are not required to distribute them solely according to geographic proximity or impact from mining activities; thus, they upheld the county's distribution method as lawful.

In the dissenting opinion for Lawrence County et al. v. Lead-Deadwood School District No. 40-1, Justice White disagreed with the majority's interpretation of South Dakota law and its application to this case. He argued that the state statute did not intend to provide a windfall for school districts at the expense of other local governmental entities when it came to sharing tax revenues from federal mineral leases. Instead, he believed that these funds should be distributed in proportion to each entity's share of total property taxes levied within their jurisdictional boundaries as intended by South Dakota lawmakers when they enacted legislation on this issue in 1975 and amended it in 1982.