In the case of Onondaga Nation v. Thacher, 1902, the Supreme Court ruled against the Onondaga Native American tribe in their claim to land in New York State. The tribe had argued that they were entitled to this territory under a treaty signed with the federal government in 1794. However, subsequent state treaties had transferred ownership of these lands to private individuals and entities over time. The court held that while it was true that only Congress could extinguish Indian title through a treaty or statute, there was no evidence suggesting such an action by Congress regarding these specific lands after 1794. Therefore, any transactions conducted by New York State were deemed valid and binding as per existing laws at those times.

The dissenting opinion in the case of Onondaga Nation v. Thacher argued that the majority's decision failed to adequately consider and respect Native American sovereignty and land rights. The dissent emphasized that treaties with Native American nations should be interpreted as they would have been understood by those nations at the time they were made, not through a lens of European legal traditions or modern interpretations. They contended that under this interpretation, it was clear that the Onondaga Nation had never ceded their lands but merely granted certain usage rights to settlers while retaining ultimate ownership themselves. Therefore, according to this view, New York State's subsequent sale of these lands was invalid because it exceeded its authority under the treaty agreements.