In November of 1910, Congress acted to sell a portion of the unallotted land, which included 750,000 acres of Chickasaw land. The Choate Case was litigated in 1911 and 1912 and was argued before the U.S. Supreme Court. The Court ruled the Chickasaws could not be taxed for 21 years based on the Atoka Agreement. The decision prevented some Chickasaws from losing their land due to their inability to pay taxes.
After World War I, inflation hit the economy and appropriations to the tribes were cut. The Indian Rights Association became more active.