The U.S. Supreme Court case Montana et al. v. Blackfeet Tribe of Indians in 1984 revolved around the issue of whether a state could impose taxes on oil and gas production on Indian reservations without explicit congressional authorization. The Blackfeet Tribe argued that such taxation was not permissible under federal law, while the State of Montana contended it had the right to tax any economic activity within its borders, including those occurring on tribal lands. In a unanimous decision, the Supreme Court sided with the Blackfeet Tribe, ruling that states cannot impose taxes on mineral extraction activities taking place on Native American reservations unless specifically authorized by Congress to do so. The court reasoned that allowing states to levy such taxes would interfere with tribes' ability to attract non-Indian capital for resource development projects and thus hinder their economic growth. This landmark decision reaffirmed tribal sovereignty over reservation resources and underscored how federal law often preempts state jurisdiction when it comes to matters involving Native American tribes.

In the dissenting opinion for Montana et al. v. Blackfeet Tribe of Indians, Justice White argued that the majority's interpretation of the 1938 Indian Mineral Leasing Act was incorrect and that it failed to consider Congress' intent when passing this law. He believed that Congress intended for states to have taxation authority over non-Indian oil and gas lessees operating on tribal lands, as long as those taxes did not interfere with tribal self-governance or federal interests in Indian affairs. The majority's decision, he contended, would unfairly deprive states of significant tax revenues they were entitled to under federal law while providing tribes with a windfall from state-imposed taxes paid by non-Indian businesses operating on their reservations.