In the United States v. The Seminole Nation case of 1936, the U.S. Supreme Court ruled in favor of the federal government and against the Seminole Nation regarding a dispute over funds owed to them under previous treaties. The court held that while it was true that certain sums had been improperly deducted from their accounts by Indian Agents, these actions were ratified by Congress through various appropriations acts which effectively settled any claims they might have had for reimbursement. Furthermore, because these deductions were made with Congressional approval, they did not constitute an illegal taking without just compensation as prohibited by Fifth Amendment rights since Congress has plenary power over Indian affairs. Therefore, even though there may have been some wrongdoing on part of individual agents or officials in handling tribal funds initially, this does not necessarily mean that legal liability can be imposed upon the government itself especially when subsequent legislative measures have already addressed such issues.

In the dissenting opinion for United States v. The Seminole Nation, Justice Cardozo disagreed with the majority's interpretation of an 1897 agreement between Congress and the Seminole Nation. He argued that this agreement did not intend to extinguish all outstanding claims by individual tribe members against their own tribal government but was instead focused on settling disputes between tribes and non-tribal entities such as states or private citizens. According to him, it would be unjust to interpret this agreement in a way that denies individuals within a tribe any legal recourse for grievances against their own tribal leaders. Furthermore, he pointed out inconsistencies in how similar agreements had been interpreted in previous cases involving other Native American tribes which further undermined his confidence in the majority's decision.