In the case of POAFPYBITTY et al. v. Skelly Oil Co., 1967, the U.S Supreme Court was asked to determine whether a lease agreement between Native American landowners and an oil company could be terminated due to non-production of oil or gas. The plaintiffs, members of the Osage Tribe in Oklahoma, argued that their lease with Skelly Oil Company should end because no production had occurred for several years. However, Skelly contended that they were not obligated to produce as long as they paid rent on time under terms agreed upon in their contract. The court ruled in favor of Skelly Oil Company stating that while federal law requires leases on Indian lands to contain provisions ensuring diligent development and operation for mineral extraction purposes; it does not mandate actual production nor provide grounds for termination when there is none. This ruling clarified how federal laws apply to contracts involving Native American lands and emphasized respect for contractual agreements even if circumstances change over time.

In the dissenting opinion for POAFPYBITTY et al. v. SKELLY OIL CO., Justice Fortas argued that the majority's decision was a misinterpretation of congressional intent behind Public Law 280, which transferred jurisdiction over certain civil and criminal matters involving Native Americans from federal to state courts. He believed that Congress did not intend to include disputes over property rights in this transfer, especially when such disputes involved non-Indians attempting to assert claims on tribal lands. Furthermore, he contended that the case should have been heard in federal court due to its significant implications for Indian sovereignty and land rights issues nationwide. The justice also criticized the majority's reliance on an overly broad interpretation of "private" civil litigation under Public Law 280 as encompassing all types of private legal disputes regardless of their potential impact on tribal self-governance or territorial integrity.