In the case of United States, as Guardian of the Hualpai Indians of Arizona v. Santa Fe Pacific Railroad Co., 1941, the Supreme Court ruled in favor of the Hualapai Tribe. The dispute arose when Santa Fe Pacific Railroad claimed ownership over a portion of land that was traditionally occupied by the tribe under an 1866 Congressional Act granting lands to railroad companies for construction purposes. However, this particular piece had been reserved for Indian use before being granted to railroads and thus should have been excluded from such grants according to federal law at that time. The court held that Congress did not intend to include Indian reservations within these land grants unless explicitly stated otherwise in legislation or treaty provisions. Therefore, it concluded that title remained with the government as trustee for Native American tribes rather than transferring it to private corporations like Santa Fe Pacific Railroad.

In the dissenting opinion for United States, as Guardian of the Hualpai Indians of Arizona v. Santa Fe Pacific Railroad Co., Justice Frank Murphy argued that the majority's decision was unjust and failed to protect Native American rights. He contended that there was clear evidence showing that the Hualapai Tribe had been in continuous possession and use of land in question long before any white settlers arrived. This, he believed, should have established their right to ownership under common law principles recognized by Congress when it passed legislation protecting Indian lands from encroachment or seizure without federal consent. Furthermore, he criticized the Court’s reliance on a technicality regarding whether or not an 1851 statute applied to this case instead of focusing on broader issues related to indigenous rights and justice.