In the 1905 case of Naganab v. Hitchcock, the U.S. Supreme Court ruled on a dispute involving land rights between Native American tribes and the federal government. The Chippewa tribe in Minnesota claimed that they were entitled to compensation for lands ceded to the United States under an 1889 agreement, arguing that these lands had been sold by the government at rates higher than those agreed upon in their treaty. However, Secretary of Interior Ethan A. Hitchcock held that no additional payments were due as per his interpretation of Nelson Act of 1889 which was intended to relocate several tribes onto smaller reservations while opening up surplus land for sale by non-Natives. The Supreme Court upheld this view and denied any further payment to be made beyond what was stipulated in original agreements with tribal representatives who signed them willingly without coercion or fraud involved from part of Government officials during negotiation process thus making it legally binding contract enforceable under law despite subsequent changes in market value over time period after its execution date.

In the dissenting opinion for Naganab v. Hitchcock, Justice Harlan argued that the majority's decision was a violation of treaty obligations and an act of bad faith on part of the U.S. government. He contended that when Congress passed legislation in 1854 to establish reservations for Chippewa Indians in Minnesota, it had effectively made a binding agreement with them which could not be unilaterally altered or revoked without their consent. The fact that some members of the tribe later left these lands did not nullify this agreement nor did it give Congress authority to open up reservation lands for settlement by non-Indians as per its 1889 Act. In his view, such actions were tantamount to seizing Indian property without due process or just compensation - both clear violations of constitutional rights afforded under Fifth Amendment.