The Northern Cheyenne Tribe v. Hollowbreast et al., 1975, was a case that revolved around the distribution of funds from land claims awarded to the Northern Cheyenne Tribe by Congress. The tribe filed suit against several tribal members (Hollowbreast and others), who had seceded from the tribe and formed their own independent group, seeking to prevent them from receiving any portion of these funds. The U.S Supreme Court ruled in favor of the Northern Cheyenne Tribe, stating that only those individuals who were enrolled as members at the time when Congress made its award should benefit from it. This decision effectively excluded Hollowbreast and his followers since they had voluntarily withdrawn their membership before this date.

In the dissenting opinion for Northern Cheyenne Tribe v. Hollowbreast et al., the justice disagreed with the majority's interpretation of a 1900 Act of Congress, which they believed did not grant jurisdiction to state courts over civil disputes involving tribal lands. The dissent argued that this act only applied to criminal cases and had no bearing on civil matters such as land disputes. They also pointed out that previous court decisions had upheld tribal sovereignty in similar situations, making it inconsistent to rule otherwise in this case. Furthermore, they contended that allowing state courts to have jurisdiction could potentially undermine tribal self-governance and infringe upon their rights as sovereign entities.