In the case of Sperry Oil & Gas Company et al. v. Chisholm et al., 1923, the U.S Supreme Court was asked to determine whether a contract for oil and gas leases on Indian lands, approved by the Secretary of Interior but later cancelled due to fraud allegations, could be reinstated without new approval from the Secretary. The court ruled in favor of Chisholm et al., holding that once a lease has been cancelled due to fraudulent practices, it cannot be revived or reinstated without fresh approval from the Secretary of Interior. This decision underscored that contracts involving Indian lands require strict oversight and regulation by federal authorities to prevent exploitation and protect tribal interests.

The dissenting opinion in the Sperry Oil & Gas Company v. Chisholm case argued that the majority's decision to uphold a lower court ruling, which held that an oil lease was invalid due to noncompliance with state law, was incorrect. The dissenters believed that this interpretation of state law was too strict and did not take into account other factors such as good faith efforts by the lessee or potential harm caused by nullifying leases retroactively. They also disagreed with the majority's view on how federal laws interacted with state regulations in this context, arguing for a more flexible approach where federal interests could override certain aspects of state law when necessary. This disagreement extended to issues related to property rights and contract enforcement as well.