In Turner v. United States and Creek Nation of Indians (1918), the U.S. Supreme Court ruled on a dispute over land allotment within the Creek Nation, an indigenous tribe recognized by federal law. The case involved a claim by Turner that he was entitled to an allotment of land as a member of the Creek Nation under treaties between them and the U.S government in 1833 and 1866, which were reinforced by subsequent legislation in 1899 and 1901. However, his application for enrollment had been denied twice before due to lack of proof about his Indian blood or descent from any enrolled Creeks. The court held that it did not have jurisdiction over this matter because Congress had given authority to determine membership eligibility solely to the Secretary of Interior through these laws; thus making him ineligible for land rights based on tribal affiliation alone without proper recognition from authorized bodies.

In the dissenting opinion for Turner v. United States and Creek Nation of Indians, Justice McKenna emphasized that the majority's decision failed to adequately consider the unique nature of Indian land allotments. He argued that these lands were not simply given as a gift but were part of a larger agreement between tribes and the U.S government, with certain conditions attached to their use and transferability. The justice believed that this context should have been taken into account when interpreting whether or not Turner had legal rights over his wife's allotment after her death. In his view, by ignoring this aspect, the court was effectively allowing an unjust enrichment at Turner’s expense while also undermining tribal sovereignty and self-determination in matters related to property rights within reservations.