In the case of Satiacum v. Washington in 1973, Robert Satiacum, a member of the Puyallup Tribe, was charged with illegal fishing under state law. He argued that his tribe's treaty rights exempted him from these regulations. The Supreme Court ruled against Satiacum and upheld his conviction for illegally catching steelhead trout off-reservation in violation of Washington State law. The court held that while treaties can grant Native American tribes special hunting and fishing privileges on reservations, they do not necessarily protect those activities outside reservation boundaries unless explicitly stated within the treaty itself.

In the dissenting opinion for Satiacum v. Washington, the justice argued that Robert Satiacum, a member of the Puyallup Tribe, should be exempt from state fishing regulations due to his tribal treaty rights. The justice contended that these treaties were intended to protect Native American tribes' traditional ways of life and livelihoods - including fishing in their ancestral waters - against encroachment by settlers and later state governments. Therefore, they believed it was unjust for states to impose restrictions on such activities without clear evidence that they are necessary for conservation purposes or other compelling reasons. They also pointed out potential issues with fairness and consistency in how these laws are applied across different tribes and individuals within them. This interpretation would prioritize upholding tribal sovereignty and historical agreements over more recent state law where conflicts arise between them.