In the case of Michigan Land and Lumber Company v. Rust, 1897, the U.S. Supreme Court was tasked with determining whether a contract for timber rights on land owned by an Indian tribe could be enforced despite not having federal approval as required by law. The Michigan Land and Lumber Company had entered into a contract with George W. Lee to purchase pine timber from lands that were part of an Indian reservation in Wisconsin but later refused to honor it when they discovered that Lee did not have federal authorization for such transactions under the Act of March 3, 1871. The court ruled against the lumber company stating that even though there was no explicit prohibition in their agreement regarding non-compliance with this act, it is implied within every contract that both parties will abide by existing laws during its execution. Therefore, since obtaining federal approval before selling tribal lands was mandatory according to prevailing legislation at the time; any contracts made without adhering to this requirement would be considered illegal and unenforceable.

In the dissenting opinion for Michigan Land and Lumber Company v. Rust, it was argued that the plaintiff's claim should not have been dismissed by lower courts. The dissenting justices believed that there were valid questions regarding whether or not the defendant had interfered with the plaintiff's property rights without due process of law, which would be a violation of their constitutional rights. They also disagreed with how previous cases were interpreted in this decision, arguing instead that those precedents supported the plaintiff’s claims rather than refuting them. Furthermore, they contended that if any ambiguity existed in interpreting these laws and contracts related to land use and lumber operations - as seemed evident given conflicting interpretations - such ambiguities should be resolved in favor of public interest rather than private gain. Thus, they felt strongly enough about these issues to voice their disagreement when majority decided otherwise.