In the 1917 case Martin v. Lankford et al., the U.S. Supreme Court dealt with a dispute over land ownership in Oklahoma. The plaintiff, Martin, claimed that he had purchased certain lands from an allottee of the Creek Nation under an agreement made prior to Congress lifting restrictions on alienation for such lands. However, after these restrictions were lifted and before any deed was executed or delivered to him by said allottee, Lankford acquired title through a foreclosure sale against this same allottee who defaulted on his mortgage payments. The court ruled in favor of Lankford stating that even though Martin's contract might have been valid if it had been fully performed before removal of restrictions (i.e., if he received the deed), it was not enforceable as per existing laws at that time since no conveyance took place until after those restrictions were removed and thus did not affect subsequent purchasers like Lankford without notice. Therefore, despite having a purchase agreement with the original owner (allottee), because there was no actual transfer of property rights when legal limitations existed prohibiting such transfers among members of Native American tribes and non-members; once these limitations were lifted anyone could legally acquire those properties including creditors like Mr.Lankford via foreclosure sales.

In the dissenting opinion for Martin v. Lankford, it was argued that the majority's decision to uphold a state law requiring voters to pay a poll tax violated the Fourteenth Amendment of the U.S. Constitution, which guarantees equal protection under the law. The dissenting justices believed that this requirement effectively disenfranchised poor citizens and disproportionately affected African Americans in violation of their constitutional rights. They also disagreed with the majority's interpretation of what constitutes a "capitation" or direct tax under Article I Section 9 Clause 4 of the Constitution, arguing that any tax imposed on individuals as a prerequisite for voting should be considered such and thus unconstitutional without apportionment among states according to population.