In the case of Lowe v. Dickson, a dispute arose over land ownership in Oklahoma between two parties: one being an individual named Lowe and the other being the Choctaw and Chickasaw Nations represented by their governor, Victor M. Locke Jr., who was substituted with his successor William H. Murray during the proceedings (Dickson). The Supreme Court had to determine whether or not Lowe's claim to certain lands under allotment patents issued by U.S Secretary of Interior were valid against tribal claims. The court ruled in favor of Dickson (representing Choctaw and Chickasaw Nations), stating that Congress did not intend for these allotments to be absolute grants of title but rather they were held in trust for Native American tribes until further legislative action was taken. Therefore, any patent granted without congressional approval would be invalid as it violated this trust relationship. This ruling reinforced federal protection over Native American lands from unauthorized allocation or sale, emphasizing that only Congress has authority to alter terms under which such lands are held.

In the dissenting opinion for Lowe v. Dickson, Justice Holmes argued that the majority's decision was based on a misinterpretation of both the facts and applicable law. He contended that Lowe had not been given adequate notice of his tax liability before his property was seized, violating due process rights under the Fourteenth Amendment. Furthermore, he disagreed with the majority’s view that this case fell within an exception to general tax laws because it involved a special assessment for local improvements. Instead, he believed this case should be governed by general principles requiring fair notice and opportunity to contest any charges before deprivation of property occurs. Thus, in his view, Lowe's lack of knowledge about potential penalties did not excuse what amounted to an unconstitutional seizure without proper notification or chance for redress.