The Metlakatla Indian Community, Annette Islands Reserve v. Egan case in 1961 involved the Metlakatla Indian community's right to fish off the coast of Alaska without state interference. The State of Alaska argued that it had jurisdiction over fishing rights and could regulate them as they saw fit. However, the U.S Supreme Court ruled in favor of the Metlakatla Indian community, stating that a federal statute gave them exclusive rights to fish in their designated waters free from state regulation or control. This decision affirmed tribal sovereignty and upheld Native American treaty rights against encroachment by states.

In the dissenting opinion for Metlakatla Indian Community, Annette Islands Reserve v. Egan, Governor of Alaska et al., Justice Frankfurter argued that Congress did not intend to grant exclusive fishing rights to the Metlakatla community when it established the Annette Island Reserve in 1891. He pointed out that such a significant privilege would have been explicitly stated in the legislation if intended by Congress. Instead, he believed that Congress simply aimed to provide a secure home for the tribe without interference from non-Indians and their commercial activities. Furthermore, he noted that granting exclusive fishing rights could potentially disrupt relations with Canada since some waters around Annette Island are international waters shared with Canada under treaty agreements.