In the case of Mountain States Telephone & Telegraph Co. v. Pueblo of Santa Ana in 1984, the Supreme Court ruled on a dispute between a telephone company and an Indian tribe over taxation rights. The Pueblo of Santa Ana had attempted to impose a tax on Mountain States for its use of tribal land to run telephone lines, which was contested by the company. The court held that while tribes do have inherent sovereignty, this does not extend to imposing taxes on non-tribal entities without express consent from Congress. This decision reaffirmed previous rulings limiting tribal authority over non-members and emphasized that any ambiguities regarding such powers should be resolved in favor of limiting rather than expanding them.

In the dissenting opinion for Mountain States Telephone & Telegraph Co. v. Pueblo of Santa Ana, Justice White disagreed with the majority's conclusion that a 1905 Act did not diminish or terminate the Santa Ana Indian Reservation in New Mexico. He argued that Congress intended to disestablish the reservation when it passed this legislation and opened up surplus lands for non-Indian settlement. The language used in the act, along with its historical context and subsequent treatment by federal authorities, suggested an intent to end tribal sovereignty over these lands according to Justice White. He also criticized the majority's reliance on ambiguous legislative history rather than clear statutory text as setting a dangerous precedent which could lead to arbitrary judicial decisions about congressional intent regarding Indian reservations.