In United States v. Chetimachas Indians, the Supreme Court of the United States held that Indian tribes are not sovereign nations and do not possess any inherent rights to their land unless they have been granted those rights by treaty or other agreement with the federal government. The case arose when a group of Native Americans from Louisiana known as the Chetimacha Tribe sued for possession of certain lands in St. Mary Parish, Louisiana which had been taken over by non-Indians without compensation being paid to them. The court found that since there was no treaty between the tribe and either France or Spain (the two countries who previously owned this land) granting them title to these lands, they did not have any legal right to it and thus could not sue for its return. Furthermore, even if such a treaty existed, it would be superseded by subsequent treaties made between various governments and other Indian tribes which recognized only those tribes' exclusive right to occupy certain areas within their respective territories; therefore making all prior agreements nullified in regards to this particular dispute.

In United States v. Chetimachas Indians, the Supreme Court was tasked with determining whether or not a treaty between the United States and certain Indian tribes had been violated by settlers who had taken possession of land that was part of the treaty agreement. The majority opinion held that since Congress had never ratified any such treaty, it could not be enforced against those settlers. However, in his dissenting opinion Justice McLean argued that even though Congress did not ratify the treaty itself, they still recognized its validity when they passed legislation to enforce it and protect tribal rights on this particular piece of land. He further argued that treaties are binding contracts between nations which should be respected regardless of congressional action or inaction; thus he concluded that these settlers were wrongfully occupying lands belonging to Native Americans as per their original agreement with the US government.