In the United States v. Navajo Nation case of 2002, the Supreme Court ruled against the Navajo Nation in a dispute over coal mining royalties. The tribe had argued that former Secretary of Interior Donald Hodel conspired with Peabody Energy to deny them fair market value for their resources in violation of trust obligations established by previous treaties and statutes. They sought $600 million in damages from lost revenue due to an allegedly unfair lease amendment approved by Hodel which reduced royalty rates from 20% to 12.5%. However, the court found no evidence that any specific statutory or regulatory provision was violated by Hodel's actions nor did they find his conduct amounted to a breach of trust under common law principles applicable to private trustees. Therefore, it held that there could be no liability on part of federal government without showing such violations or breaches.

In the dissenting opinion for United States v. Navajo Nation, Justice Ginsburg argued that the majority's decision failed to recognize and respect the trust relationship between the U.S. government and Native American tribes, specifically in this case, with Navajo Nation. She contended that by ignoring evidence of improper influence on a coal lease amendment approval process involving former Secretary of Interior Donald Hodel and Peabody Coal Company - which led to an unfavorable deal for Navajo Nation - it was not consistent with federal fiduciary responsibilities towards tribal nations under established law. Furthermore, she criticized how the majority interpreted statutes related to Indian affairs too narrowly rather than considering broader principles of fairness and equity inherent in trust relationships. Thus, she believed that Navajo Nation should have been allowed damages from lost revenue due to alleged breach of trust by federal officials.