The U.S. Supreme Court case Payne, Secretary of the Interior, et al. v. United States ex rel. Newton in 1920 revolved around a dispute over land rights and mineral resources on Native American reservations in Oklahoma under the jurisdiction of the Department of Interior's Bureau of Indian Affairs (BIA). The plaintiff, Newton, claimed that he was entitled to oil and gas royalties from his allotted lands within these reservations based on an 1891 law which granted such rights to individual tribal members upon allotment. However, BIA officials argued that subsequent laws had transferred those rights to tribes collectively rather than individuals. The Supreme Court ruled in favor of Newton stating that Congress did not intend for later legislation to strip individual tribe members' property rights without clear language indicating this intention - something absent from relevant statutes at issue here. This decision reinforced protections for Native American property owners against potential government overreach while also clarifying how courts should interpret Congressional intent when it comes to changes in statutory law affecting established property interests.

In the dissenting opinion for Payne, Secretary of the Interior, et al. v. United States ex rel. Newton (1920), Justice McReynolds argued that Congress did not intend to grant oil and gas rights on allotted lands to individual Native Americans under the Act of 1906 but rather intended those resources to be held in trust by the government for their collective benefit. He believed that this interpretation was consistent with previous legislation and court decisions aimed at protecting tribal interests from exploitation. Furthermore, he disagreed with majority's view about "surplus lands," asserting it contradicted established legal principles regarding property rights and ignored historical context surrounding allotment policy which sought assimilation through land ownership while preserving valuable resources like minerals for communal use within tribes.