In the 1916 case of Mason et al. v. United States, the Supreme Court ruled on a dispute regarding land ownership in Oklahoma. The plaintiffs, members of the Choctaw and Chickasaw tribes, claimed that they were entitled to certain lands under treaties made with their tribes by the U.S government in 1830 and 1866. However, these lands had been allotted to other individuals under an act passed by Congress in 1902 which aimed at dissolving tribal governments and allotting communal Indian lands to individual tribe members as part of a policy known as "Indian assimilation". The court held that while it was true that earlier treaties did promise this land to these tribes, later legislation (including acts from both Congress and local authorities) superseded those promises due to changes in public policy towards Native American affairs over time. Therefore, despite previous treaty obligations promising them this territory indefinitely for farming purposes without interference or encroachment by non-tribal citizens or corporations unless voluntarily ceded back by said nations themselves through formal agreement ratified via majority vote among all adult male inhabitants thereof; such agreements could be unilaterally altered or nullified entirely if deemed necessary for broader societal interests according national legislative prerogative alone regardless any prior contractual commitments otherwise stipulated therein beforehand.

In the dissenting opinion for Mason et al. v. United States, Justice Holmes disagreed with the majority's decision to uphold a conviction based on conspiracy to defraud the government by obstructing its functions. He argued that there was no evidence of an actual intent to interfere with or obstruct governmental operations and thus, it was unjustifiable to convict solely based on this premise. Furthermore, he contended that if every act which might be deemed as potentially interfering were considered criminal, then many innocent acts could also fall under such broad interpretation leading to unwarranted prosecutions. Therefore, he believed that without clear proof of intentionality in obstruction or interference in governmental functionings, it is inappropriate and unfair for such actions alone to constitute a crime punishable by law.