In the case of Mitchell et al. v. United States in 1924, the Supreme Court ruled on a dispute involving land ownership and mineral rights in Oklahoma. The plaintiffs were members of the Choctaw and Chickasaw tribes who had been given allotments of land by Congress under an agreement that also reserved certain mineral rights for tribal use. When oil was discovered on their lands, they sued to prevent non-tribal leaseholders from extracting it without their consent or compensation. The court held that while Congress had intended to protect tribal interests, it did not intend to give individual tribe members exclusive control over minerals found beneath allotted lands; rather these resources were meant to be shared among all tribe members collectively as per traditional practices. Therefore, even though individual tribe members owned surface rights to their respective parcels of land, they could not unilaterally exploit sub-surface minerals without regard for collective tribal interests or agreements made with third parties like oil companies by authorized representatives acting on behalf of both tribes as a whole.

In the dissenting opinion for Mitchell et al. v. United States, Justice McReynolds argued that the majority's decision to uphold a federal law prohibiting alcohol on tribal lands infringed upon Native American sovereignty and self-governance. He contended that Congress did not have the authority to impose such restrictions without explicit consent from tribes themselves, as they are separate political entities with their own inherent powers of self-government. Furthermore, he expressed concern about potential overreach by federal authorities into matters traditionally handled by tribal governments under treaties and other agreements with the U.S government. This ruling, according to him, set a dangerous precedent for future interference in tribal affairs beyond what was intended or permitted by existing laws and treaties.