United States v. Council of Keokuk was a Supreme Court case that dealt with the issue of tribal sovereignty. The case involved the Sac and Fox Indians, who had signed a treaty with the United States in 1836. The treaty granted the United States the right to purchase land from the Indians, but it also granted the Indians the right to form a tribal government. The United States argued that the tribal government had no legal authority and that the United States had the right to purchase the land without the consent of the tribal government. The Supreme Court disagreed, ruling that the tribal government had the right to negotiate with the United States and that the United States could not purchase the land without the consent of the tribal government. The Court also held that the tribal government had the right to exercise its own sovereignty and that the United States could not interfere with the tribal government's decisions. The ruling established the principle of tribal sovereignty, which has been upheld in subsequent Supreme Court cases.

In United States v. Council of Keokuk, the Supreme Court was tasked with deciding whether or not a treaty between the United States and certain Native American tribes had been violated by one of those tribes. The majority opinion held that the tribe in question had indeed breached its obligations under the treaty, but Justice Field dissented from this decision. He argued that while it may have seemed like a breach to an outsider looking in, there were extenuating circumstances which should be taken into consideration when determining if any violation occurred. Specifically, he noted that since Congress had failed to provide funds for annuities promised by the treaty as well as other necessary supplies for tribal members' subsistence needs, it would be unfair to hold them accountable for their actions without taking these factors into account first. Furthermore, he argued that even if some form of compensation was provided after-the-fact it could never make up for all they lost due to Congress's inaction and thus no violation should be found on behalf of the tribe itself.