In the 1890 case of Red River Cattle Company v. Needham, the U.S. Supreme Court was tasked with resolving a dispute over land ownership in Texas between the Red River Cattle Company and an individual named Needham. The cattle company claimed that it had purchased lands from Choctaw and Chickasaw tribes which were later sold to Needham by Congress through legislation passed in 1872 and 1883. However, these laws did not recognize any previous private purchase agreements made with Native American tribes for their communal lands without federal approval as per Indian Nonintercourse Act (1790). Therefore, the court ruled against Red River Cattle Company stating that its purchases were invalid because they violated this act since there was no evidence of federal approval for them at time of transaction or afterwards. This decision upheld Congressional power to regulate commerce with Native American tribes while also reinforcing legal principles regarding property rights.

The dissenting opinion in the case of Red River Cattle Company v. Needham argued that the majority's decision was inconsistent with previous rulings and established principles of law. The dissent contended that a contract for sale should be considered valid even if it does not specify an exact price, as long as there is a clear method to determine the price later on. In this case, they believed such a mechanism existed through market prices at delivery time or by arbitration if disagreements arose. They also disagreed with the majority's interpretation of Texas law regarding land ownership rights, arguing that it did not require physical possession for one to claim ownership rights over property but merely required proof of legal title or right to possession.