In the 1983 case of Three Affiliated Tribes of the Fort Berthold Reservation v. Wold Engineering, P.C., et al., the U.S Supreme Court ruled on a jurisdictional dispute between state and tribal courts. The Three Affiliated Tribes had sued Wold Engineering in tribal court for breach of contract and fraud related to work done on their reservation. However, Wold argued that only state courts had jurisdiction over such cases involving non-Indians on Indian reservations due to Public Law 280 (a federal law granting certain states criminal and civil jurisdiction within Indian country). The Supreme Court disagreed with this interpretation, ruling that Public Law 280 did not automatically grant North Dakota (where the reservation was located) exclusive or pre-emptive civil adjudicatory authority over disputes arising out of activities occurring on an Indian reservation simply because it involved a non-member party. Instead, they held that tribes retain inherent sovereign power to exercise some forms of civil jurisdiction over non-Indians even on their reservations unless specifically limited by Congress.

In the dissenting opinion for the case of Three Affiliated Tribes of The Fort Berthold Reservation v. Wold Engineering, P.C., et al., Justice O'Connor argued that state courts should not have jurisdiction over civil disputes involving Native American tribes on reservation lands unless Congress explicitly grants such authority. She contended that the majority's decision was inconsistent with previous rulings and principles regarding tribal sovereignty and federal law supremacy in matters relating to Indian affairs. Furthermore, she expressed concern about potential negative impacts on tribal self-government and economic development due to increased uncertainty surrounding legal jurisdictions over reservations. In her view, this could deter investment and undermine efforts by tribes to manage their own affairs independently from state interference.