In the United States v. Mazurie et al., 1974, the Supreme Court ruled that Congress had not unconstitutionally delegated its legislative power by allowing an Indian tribe to regulate liquor sales on their reservation. The case arose when a bar owned by William and Audrey Mazurie in Fort Washakie, Wyoming was denied a renewal of its liquor license by the Wind River Tribes. The couple continued to sell alcohol without a license and were subsequently convicted under federal law for selling alcohol on tribal land without permission from both federal authorities and tribal leaders. On appeal, they argued that Congress could not delegate regulatory authority over liquor sales to tribes because they are private entities rather than sovereign nations or states within the U.S federation system. However, this argument was rejected as it failed to recognize tribes' inherent powers of self-government which include regulating activities within their territories.

In the dissenting opinion for United States v. Mazurie et al., Justice William O. Douglas argued that Congress had overstepped its bounds by delegating regulatory power to an Indian tribe, in this case, the ability to regulate liquor sales on tribal land. He contended that such delegation was unconstitutional because it gave legislative powers to a group not recognized as having governmental authority under the Constitution. Furthermore, he expressed concern about potential abuse of power and lack of accountability if tribes were allowed unchecked regulatory control within their territories without any clear standards or guidelines from Congress.