In the case of Queenan v. Oklahoma in 1902, the U.S. Supreme Court ruled on a dispute involving land ownership rights under tribal law and federal law. The plaintiff, Queenan, was an intermarried citizen of the Choctaw Nation who had purchased land from a member of that tribe before Oklahoma became a state. After statehood, however, non-Indians were prohibited from owning property within Indian Territory without express permission from Congress or through inheritance laws outlined by tribal treaties with the United States government. The defendant argued that since Queenan was not an enrolled member of any Native American tribe nor did he have congressional approval to own such lands; his purchase was therefore invalid according to federal law and should be returned back to its original owner or their heirs. The court agreed with this argument stating that while it recognized marriages between Indians and non-Indians as valid under tribal customs/laws; these unions did not automatically confer upon them all privileges/rights enjoyed by native citizens including unrestricted property ownership within reservation boundaries unless specifically granted by treaty provisions or acts passed by Congress recognizing such rights.

The dissenting opinion in the case of Queenan v. Oklahoma argued that the majority's decision was inconsistent with previous rulings and interpretations of the law regarding taxation. The dissenting justices believed that there should be a clear distinction between taxes imposed on property and those levied on privileges or franchises, which they felt had been blurred by this ruling. They also disagreed with how the court interpreted "due process," arguing it did not mean simply following prescribed forms or proceedings, but rather ensuring fairness and justice for all parties involved. Furthermore, they contended that if a tax is unjustly assessed or collected without proper authority, then due process has been violated regardless of whether procedures were followed correctly. This interpretation would have allowed Mr. Queenan to challenge his tax assessment as unconstitutional under state law before being forced to pay it.