The Metlakatla Indian Community, Annette Island Reserve v. Egan, Governor of Alaska case in 1959 revolved around the fishing rights of the Metlakatla Indian community in Alaska. The state had attempted to regulate their salmon fishery operations by requiring them to obtain a permit and adhere to certain restrictions. The tribe contested this regulation, arguing that they were exempt from such laws due to federal protection under an 1891 Act which established their reservation. They claimed that this act granted them exclusive fishing rights within their territory without interference from state regulations or limitations. The U.S Supreme Court ruled in favor of the Metlakatla Indians stating that as per Congress's intent when establishing the reservation, it was clear they intended for these natives to be self-sufficient and independent economically through fishing activities on and off reserve land without any hindrance from State law unless specifically authorized by Congress itself.

In the dissenting opinion for Metlakatla Indian Community, Annette Island Reserve v. Egan, Governor of Alaska et al., Justice Frankfurter disagreed with the majority's interpretation of Congress' intent in granting fishing rights to the Metlakatla Indian community. He argued that there was no clear evidence that Congress intended to grant exclusive commercial fishing rights within a 3,000-foot zone around Annette Island. Instead, he believed that such an interpretation went beyond what could reasonably be inferred from the language and history of relevant legislation. Furthermore, he contended that this ruling would set a dangerous precedent by allowing federal courts to infer Congressional intent without explicit statutory authority or historical context supporting such conclusions.