In the Pueblo of Santa Rosa v. Fall case in 1926, the Supreme Court ruled on a dispute between an indigenous community and the Secretary of Interior regarding land rights. The Pueblo of Santa Rosa claimed that they had been wrongfully dispossessed from their ancestral lands by non-Indian settlers who were granted patents to these lands by the U.S government. They argued that as per Spanish law (which was applicable when New Mexico became part of US territory), they held aboriginal title to these lands which could not be extinguished without their consent or through federal legislation. However, the court rejected this argument stating that upon acquiring New Mexico, United States laws replaced those previously in force and hence any claims based on Spanish law were invalid. Furthermore, it stated that Congress had plenary power over Indian affairs including tribal property rights; thus it could grant patents for Indian lands even if tribes continued occupying them.

In the dissenting opinion for The Pueblo of Santa Rosa v. Fall, it was argued that the majority's decision failed to properly consider and respect the sovereignty and property rights of Native American tribes. The dissenters contended that under Spanish law, which governed at the time when New Mexico became a U.S territory, Indian pueblos were recognized as separate political entities with distinct land rights. They maintained that these rights should have been preserved when New Mexico transitioned into U.S jurisdiction. Furthermore, they disagreed with the majority's interpretation of Congressional intent in relation to pueblo lands; arguing instead that Congress had intended to protect these lands from encroachment by non-Indians rather than subject them to federal control or disposal without tribal consent.