In the case of Work, Secretary of the Interior v. United States Ex Rel. Mosier et al., 1922, the Supreme Court ruled on a dispute over land rights in Oklahoma. The Osage Tribe had been granted ownership of mineral resources beneath their reservation by Congress in 1906 but later leased these rights to private oil companies for development and extraction purposes. However, when some tribal members died without heirs or wills, there was disagreement about who should inherit these leases - whether they should revert back to the tribe as a whole or be passed onto other individual tribal members under state inheritance laws. The Secretary of Interior argued that since Congress had given this land "in trust" to the tribe collectively rather than individually, it meant any unclaimed property would return to communal ownership instead of being subject to state law distribution among surviving relatives. The Supreme Court agreed with this interpretation and held that such leasehold interests were part of an ongoing trust relationship between federal government and Native American tribes which superseded local probate rules. Therefore, undistributed assets from deceased Osage members' estates must benefit all remaining tribal beneficiaries equally rather than enriching only certain individuals through intestacy succession.

In the dissenting opinion for Work, Secretary of the Interior v. United States ex rel. Mosier et al., Justice McReynolds argued that the majority's decision was inconsistent with previous rulings and failed to respect Congress' authority over public lands. He contended that under existing laws, oil deposits discovered on public land were not subject to private ownership until after a patent had been issued by the government. Therefore, he believed that any rights acquired by Mosier through his lease from an Indian tribe did not include oil reserves found beneath tribal lands because those resources remained in federal control until formally transferred via patent. In essence, Justice McReynolds disagreed with the majority’s interpretation of property rights related to mineral resources on public lands and maintained a stricter adherence to statutory law.