In the case of Williams et ux. v. Lee, the U.S Supreme Court ruled in favor of Native American self-governance on tribal lands. The dispute began when a non-Native American store owner named Lee sued an Navajo couple, the Williamses, for unpaid debts in Arizona state court. The couple argued that since they lived on a reservation and incurred their debt there, only tribal courts had jurisdiction over their case according to federal law and treaties between tribes and the U.S government. The Arizona court disagreed but upon appeal by the defendants, it was overturned by higher courts culminating with this 1958 Supreme Court decision which held that state courts have no authority over civil disputes involving reservation Indians where such disputes arise out of events occurring within Indian country.

In the dissenting opinion for Williams et ux. v. Lee, Justice Whittaker argued that the majority's decision to uphold tribal court jurisdiction over a non-Indian trader operating on a reservation was inconsistent with previous rulings and federal law. He contended that while it is true that Indian tribes possess inherent sovereignty, this power has been significantly limited by treaties and statutes enacted by Congress. According to him, these laws have subjected Indians living on reservations to state civil jurisdiction in many respects, including contract disputes involving non-Indians like the one at issue in this case. Therefore, he believed that Arizona courts should have had jurisdiction over such matters rather than Navajo tribal courts as decided by the majority.