In the case of United States on the Relation of Hall v. Payne, Secretary of the Interior in 1920, a dispute arose over land ownership rights between private citizen Hall and an Indian tribe. The Supreme Court was asked to determine whether or not Hall had legal claim to certain lands that were part of an Indian reservation under federal protection. The court ruled against Mr. Hall stating that he did not have any valid claims because his alleged title originated from a tribal member who had no authority to sell or transfer property without approval from Congress as stipulated by non-intercourse acts protecting Native American tribes' lands from unauthorized sales or transfers. Therefore, it was determined that only Congress has jurisdiction over these matters and can approve such transactions involving protected tribal lands.

In the dissenting opinion for United States on the Relation of Hall v. Payne, Secretary of the Interior, 1920 case, it was argued that Congress had not intended to grant absolute power over Indian lands to the Secretary of Interior without any judicial review. The dissenting justices believed that such an interpretation would be contrary to principles of justice and equity. They maintained that if a decision by the Secretary is arbitrary or capricious or made in bad faith, then it should be subject to review by courts. Furthermore, they asserted that there were no explicit provisions in Congressional acts which suggested immunity from judicial scrutiny for decisions made by administrative officers regarding Indian lands. Therefore, they disagreed with majority's view and held that judiciary has a role in ensuring fairness and legality even when dealing with matters related to administration's control over tribal properties.