In the United States Ex Rel. Brown v. Lane, Secretary of the Interior case in 1913, a dispute arose over land allotments on Indian reservations under the General Allotment Act of 1887 (also known as Dawes Act). The plaintiff, an enrolled member of the Osage Tribe named William Fletcher Brown, claimed that he was entitled to another allotment after relinquishing his original one due to marriage dissolution. However, Franklin K. Lane - then serving as Secretary of Interior - denied this claim based on an interpretation that each tribal member could only receive one allotment regardless of circumstances. Brown filed a petition for writs mandamus and prohibition against Lane's decision with Supreme Court arguing it violated his rights under Dawes Act and Osage Allotment Act which allowed multiple allotments in certain conditions including divorce or death. The Supreme Court ruled in favor of Brown stating that while generally Dawes act limited members to single land allocation; specific provisions within Osage Allotment act permitted additional allocations upon meeting certain criteria like marital status change through divorce or widowhood thus making him eligible for second grant.

In the dissenting opinion for United States ex rel. Brown v. Lane, Secretary of the Interior, 1913, Justice Holmes disagreed with the majority's decision to deny citizenship to a Native American who had left his tribe and integrated into white society. He argued that once an individual has severed ties with their tribal community and fully assimilated into mainstream culture, they should be considered citizens under U.S law without needing explicit congressional approval or naturalization process as required by the Indian Citizenship Act of 1924. Furthermore, he contended that denying such individuals citizenship was contrary to principles of justice and equality inherent in U.S law because it effectively created a separate class of people who were denied basic rights despite living within U.S borders and adhering to its laws.