In the case of United States and The Kiowa Indians v. Martinez in 1904, the U.S Supreme Court ruled on a dispute over land rights between an individual named Martinez and the Kiowa Indian tribe. The court held that under federal law, Native American tribes have sovereignty over their lands unless Congress explicitly states otherwise. In this case, there was no Congressional act to suggest that the Kiowas had lost control or ownership of their lands. Therefore, any claim by Martinez to these lands was invalid as he could not demonstrate any legal right or title to them under either state or federal law. This decision reinforced tribal sovereignty and affirmed that only Congress has authority over tribal affairs.

In the dissenting opinion for United States and The Kiowa Indians v. Martinez, it was argued that the majority's decision to deny compensation to Martinez for his seized property contradicted previous rulings where tribes were held liable for their actions. The dissent emphasized that Indian tribes should not be immune from lawsuits in federal courts when they violate individual rights or property interests. It was contended that this immunity undermines the principle of equality before law and leaves victims without a remedy. Furthermore, it was suggested that such blanket immunity could potentially encourage unlawful behavior by tribal entities who know they cannot be sued in federal court. Thus, according to this view, holding tribes accountable would better serve justice and uphold rule of law principles.