In the United States v. Omaha Tribe of Indians case in 1919, the Supreme Court ruled on a dispute over land ownership between the U.S. government and the Omaha Tribe of Indians. The tribe claimed that they were entitled to compensation for lands taken by the government under an 1854 treaty which had not been paid for at fair market value. The court held that while there was no explicit provision in any statute or treaty requiring payment at fair market value, it was implied from general principles of justice and equity that such should have been made when tribal lands were acquired by cession to federal authorities. Therefore, it found in favor of the Omaha Tribe and ordered compensation be given based on this principle.

In the dissenting opinion for United States v. Omaha Tribe of Indians, Justice McReynolds disagreed with the majority's decision to award compensation to the Omaha Tribe for land taken by Congress in 1882. He argued that there was no legal basis for this claim as it had been more than three decades since the alleged taking occurred and any claims should have been made at that time. Furthermore, he contended that Congress acted within its rights when it took possession of tribal lands because they were held "in trust" by the government on behalf of Native American tribes - a status which allowed such actions under certain circumstances without constituting an illegal seizure. The justice also pointed out inconsistencies in how similar cases involving other tribes had been handled, suggesting a lack of fairness and uniformity in court decisions regarding indigenous land rights.