The White Mountain Apache Tribe v. Bracker case in 1979 revolved around the issue of whether a state could impose its taxes on non-tribal entities performing operations within tribal reservations. The Fort Apache Timber Company, owned by the White Mountain Apache Tribe but managed by a federal agency, contracted with two non-native companies for logging services. Arizona attempted to impose motor carrier license and use fuel taxes on these companies which led to this dispute. The Supreme Court ruled in favor of the tribe, stating that although states have authority under certain circumstances to tax activities occurring on tribal lands involving non-members, it was precluded here due to federal law and policy intending exclusive governance over Indian affairs by the Federal Government and tribes themselves without interference from states. This ruling reinforced tribal sovereignty rights while limiting state jurisdiction over economic activity happening within reservations.

In the dissenting opinion for White Mountain Apache Tribe v. Bracker, Justice Rehnquist argued that the majority's decision was inconsistent with previous rulings and overly broad in its interpretation of federal law. He contended that while Congress has plenary power over Indian affairs, it does not mean states are completely barred from exercising their authority on reservations unless explicitly prohibited by Congress. According to him, there is no clear evidence showing congressional intent to preclude state taxation in this case. Furthermore, he disagreed with the majority's view about tribal sovereignty being a significant factor as he believed it should only be considered when there is ambiguity regarding congressional intent or where applying state law would interfere with federal policies. In his view, neither condition existed here; hence Arizona’s motor carrier license tax and use fuel tax should apply to non-Indian logging companies operating on reservation lands under contracts with tribes.