In the 1976 case United States et al. v. County of Fresno, the Supreme Court addressed a dispute over whether certain lands held in trust by the federal government for Native American tribes were subject to local property taxation. The county had imposed taxes on these lands, arguing that they were not exempt from such levies because they did not fall under any recognized exemption category and because their use for agricultural purposes constituted a commercial activity rather than a governmental one. However, the court ruled against this argument, holding that these lands could not be taxed by local authorities as long as they remained in trust status with the federal government. This decision was based on principles of tribal sovereignty and federal supremacy over state law when it comes to matters involving Native American affairs.

The dissenting opinion in the United States v. County of Fresno case argued that the majority's decision to allow federal agencies to bypass state water laws was a misinterpretation of Congress' intent when it passed the Reclamation Act of 1902. The dissenters believed that this act did not grant such sweeping powers, but rather intended for cooperation between federal and state authorities regarding water rights and usage. They contended that by ignoring California's established water rights system, which had been functioning effectively for years, the majority undermined states' authority over their own natural resources without clear congressional mandate. This interpretation could potentially lead to conflicts between federal projects and existing local or private rights holders who have relied on these systems for decades.