The United States v. Choctaw Nation and Chickasaw Nation case in 1900 revolved around a dispute over the distribution of funds from land sales under an 1866 treaty between the U.S. government, Choctaw, and Chickasaw Nations. The Supreme Court was asked to interpret certain provisions of this treaty regarding how proceeds from these lands should be divided among the tribes. The court held that both tribes were entitled to share equally in all funds derived from leasing or selling their common property based on stipulations within the treaty itself which stated that any advantages gained would be shared jointly by both nations irrespective of population size differences. This decision resolved a long-standing disagreement about fund allocation between these two Native American nations.

In the dissenting opinion for United States v. Choctaw Nation and Chickasaw Nation, Justice Harlan argued that the Court's majority decision was incorrect in its interpretation of the 1830 Treaty of Dancing Rabbit Creek. He believed that this treaty did not grant full ownership rights to the Choctaw and Chickasaw Nations over lands west of their original territories, but merely provided them with a right to occupy these lands. According to him, Congress retained ultimate sovereignty over these territories and could dispose of them as it saw fit without compensating the tribes. Furthermore, he contended that even if one were to accept that full title had been granted by this treaty, subsequent treaties modified those terms such that any claim for compensation from sales made after 1866 would be invalid.