In the case of Reuben Quick Bear v. Leupp, Commissioner of Indian Affairs in 1907, the U.S. Supreme Court ruled that funds generated from leasing tribal lands could be used to support sectarian schools on reservations without violating constitutional prohibitions against government funding for religious activities. The court reasoned that these funds were not public money but rather belonged to the tribes themselves and thus their use was a matter of tribal discretion under federal supervision. This decision upheld an earlier ruling by a lower court which had dismissed Quick Bear's suit seeking to prevent such use of lease revenues.

The dissenting opinion in the case of Reuben Quick Bear v. Leupp, Commissioner of Indian Affairs argued that the funds derived from sales or leases of tribal lands should be considered public money and not private property belonging to individual tribe members. The justices contended that these monies were held by the government in trust for all Indians collectively, rather than as a collection of separate accounts for each member. They believed this interpretation was consistent with previous court decisions and federal policies regarding Native American tribes. Therefore, they disagreed with the majority's ruling that allowed these funds to be used for sectarian education without violating constitutional prohibitions against using public money for religious purposes.