The U.S. Supreme Court case, Michael E. Lincoln, Acting Director of the Indian Health Service, et al. v. Grover Vigil et al., 1992 revolved around a dispute over funding allocation by the Indian Health Service (IHS). The IHS had traditionally allocated funds for health services to various tribes based on their population size and need but decided to divert some of these funds towards nationwide programs instead. A group of tribes sued IHS arguing that this reallocation violated both federal law and their rights as sovereign entities under treaties with the United States government. In its decision, the Supreme Court sided with IHS stating that Congress had given it broad discretion in allocating resources among different healthcare needs within Native American communities; therefore, its decision to shift funds did not violate any laws or treaty obligations.

In the dissenting opinion for Lincoln v. Vigil, Justice Blackmun argued that the majority's decision allowed an agency to make significant changes in policy without any form of judicial review. He believed this was a violation of the Administrative Procedure Act (APA), which requires agencies to provide notice and opportunity for comment when making such changes. Furthermore, he contended that by allowing Indian Health Service (IHS) to reallocate funds from one program to another without public input or oversight, it undermined Congress' power over appropriations and violated principles of democratic accountability. The justice also expressed concern about potential harm caused by abrupt termination of services due to sudden funding shifts within IHS.