In Magnan v. State, the Oklahoma Court of Criminal Appeals concluded that a parcel of land in which Seminole Indians retained 4/5 of mineral rights was still no longer Indian Country. The case is interesting for two reasons. First, the whole debate about Indian Country:

This Court considered a similar question in Murphy v. State, 2005 OK CR 25, 124 P.3d 1198.  In Murphy, a murder occurred on a state road that at one time had been Indian allotted land.  Over time, the surface estate on which the road was located, and 11/12ths of the mineral estate, had been conveyed to non-Indians.  Applying a contacts and interests analysis analogous to the familiar “minimum contacts” test set out in International Shoe Co. v. State of Washington, 326 U.S. 310, 316, 66 S.Ct. 154, 158, 90 L.Ed. 95 (1945), the Murphy court concluded that the Oklahoma’s contacts and interests in the surface property overwhelmed any fractional interest the Indian heir of the original allottee owned in the unseen mineral estate.  According to Murphy, that conclusion was necessary because allowing an unobservable fractional interest to control the enforcement of laws on the surface of a property would lead to a checkerboard of alternating jurisdictions that would seriously burden the administration of state and local governments.  Murphy, ¶¶ 42-43, 1206.  Murphy held, therefore, that a fractional interest in an unobservable mineral interest is a contact with the surface estate that is insufficient to deprive the State of Oklahoma of criminal jurisdiction.  Id. ¶ 42, 1206.

But more amazingly, the court had the benefit of a federal court case reaching the same outcome 10 years earlier regarding the same property!:

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