In the case of Perryman v. Woodwar in 1914, the U.S Supreme Court was tasked with determining whether a certain piece of land belonged to an individual or if it was part of Creek Nation's tribal lands. The plaintiff, a member of the Creek tribe named Legus C. Perryman, claimed that he had been granted this parcel by virtue of his membership in the tribe and argued that it should be exempt from taxation as per federal law regarding Native American territories. However, defendant J.H Woodward contended that this particular plot did not fall under tribal jurisdiction because it had been allotted to another person who later sold it off - thus making it taxable property according to Oklahoma state laws where the land is located. The court ruled against Perryman stating that once Indian lands are allotted and then subsequently sold to non-Indians they lose their status as Indian Country and become subject to state law including taxation.

The dissenting opinion in the case of Perryman v. Woodwar argued that the majority's decision was inconsistent with previous rulings and legal principles regarding land ownership rights. The dissenting justices believed that the plaintiff, a Native American woman named Lucy Perryman, should have been allowed to maintain possession of her inherited allotment of tribal lands despite not having formal documentation or title deeds. They contended that under federal law and treaties with Native American tribes, members were entitled to occupy and use their allotted lands without interference from non-Native settlers or speculators like defendant Woodward. Furthermore, they disagreed with the majority's interpretation of an 1898 act regulating Indian affairs as allowing for involuntary sales or transfers of such allotments against their owners' wishes before a certain period had elapsed. Instead, they held this provision was intended only to prevent voluntary alienation by naive or unscrupulous tribe members themselves within said timeframe.