In the case of United States ex rel. Knight v. Lane, Secretary of the Interior in 1912, a dispute arose over land ownership rights under an Indian allotment act. The plaintiff was a member of the Choctaw tribe and claimed that he had been unfairly denied his right to select land as part of an allotment due to misinterpretation by officials from the Department of Interior regarding eligibility criteria for such selection. The Supreme Court ruled against Knight, upholding that only those who were alive at the time when tribal rolls were prepared (1896) could claim lands under this act; descendants born after this date did not have these rights even if their parents died before making any selections themselves.

In the dissenting opinion for United States ex rel. Knight v. Lane, Secretary of the Interior, 1912, Justice Holmes argued that Congress had not intended to grant citizenship to Native Americans who were living on reservations and maintaining tribal relations when it passed a law in 1887 allotting them individual parcels of land. He believed that the majority's interpretation of this law was incorrect because it failed to take into account its historical context and purpose: namely, encouraging Native Americans to abandon their traditional ways of life and assimilate into mainstream American society. According to Justice Holmes, if Congress had wanted these individuals to become citizens immediately upon receiving their allotments - regardless of whether they continued living as members of their tribes - it would have said so explicitly in the statute.