In the case of United States ex rel. Chapman, Secretary of the Interior v. Federal Power Commission et al., 1952, the Supreme Court was asked to determine whether or not a license from the Federal Power Commission (FPC) was required for a hydroelectric project on tribal lands. The Department of Interior argued that it had exclusive jurisdiction over such projects under federal law and thus did not need FPC approval. However, the court ruled in favor of FPC stating that even though these were tribal lands held in trust by federal government, they still fell within navigable waters as defined by Federal Water Power Act (FWPA). Therefore, any power project on them would require an FPC license according to FWPA provisions which aimed at comprehensive control over water resources development including power generation.

In the dissenting opinion for UNITED STATES EX REL. CHAPMAN, SECRETARY OF THE INTERIOR, v. FEDERAL POWER COMMISSION ET AL., 1952, Justice Douglas argued that the Federal Power Commission (FPC) had overstepped its authority by granting a license to construct and operate a hydroelectric project on tribal lands without obtaining consent from the tribe or approval from Congress. He contended that this decision violated both federal law and treaty rights of Native American tribes. The majority's interpretation of relevant statutes was seen as flawed because it failed to recognize these protections for tribal sovereignty and property rights. Furthermore, he expressed concern about potential negative impacts on natural resources in Indian territories due to such projects approved without proper consultation with affected tribes.