The Supreme Court case Work, Secretary of the Interior v. Braffet, Administrator in 1927 revolved around a dispute over oil and gas leases on Osage Indian lands in Oklahoma. The Secretary of the Interior had cancelled certain leases made by tribal members to private companies after finding that they were obtained through fraud or undue influence. However, an administrator for one of the deceased tribal members argued that this action was beyond his authority as it violated property rights under state law. The court ruled in favor of the Secretary, stating that he did have such power since Congress had granted him broad discretion to manage these lands for the benefit of tribe members and prevent exploitation. It further held that while individual Indians could lease their land allotments under supervision from federal officials, they couldn't do so independently without risking cancellation if found detrimental to their interests.

In the dissenting opinion of Work, Secretary of the Interior v. Braffet (1927), Justice Holmes argued that Congress had not intended to give Native Americans full ownership rights over their allotted lands but rather a limited right akin to a life estate. He contended that this interpretation was consistent with previous court decisions and Congressional intent as reflected in various statutes governing Indian affairs. Furthermore, he disagreed with the majority's view that any ambiguity in these laws should be resolved in favor of Native Americans, arguing instead for an approach based on legislative history and precedent. Finally, he expressed concern about potential negative consequences if tribes were allowed unrestricted control over their lands without federal oversight or protection against exploitation by non-Native interests.