The U.S. Supreme Court case Salazar v. Ramah Navajo Chapter (2011) centered on whether the federal government must pay in full each contract it enters into with a Native American tribe under the Indian Self-Determination and Education Assistance Act, even if Congress has not appropriated enough funds to cover all such contracts. The court ruled 5-4 in favor of the tribes, stating that when the federal government contracts with tribal governments, it is obligated to fulfill those contractual obligations fully as long as they are within "contractual limits". This ruling was significant because it affirmed that tribal contractors could seek legal recourse for unpaid costs from contracted services provided by them but were not paid due to insufficient Congressional appropriations.

In the dissenting opinion for Salazar v. Ramah Navajo Chapter, Justice Roberts, joined by Justices Ginsburg and Thomas, argued that the majority's decision contradicted previous rulings which held that government agencies are not required to pay out more than Congress has appropriated for a particular program. The dissenters contended that this ruling would encourage federal agencies to overcommit funds in contracts with tribal governments without ensuring there were enough appropriations from Congress to cover these commitments. They also expressed concern about potential negative impacts on other programs funded through the same appropriation if an agency is forced to honor all its contractual obligations despite insufficient funding from Congress. Furthermore, they disagreed with the majority’s interpretation of contract law principles as applied in this case.