In the case of Adams v. Cowen (1899), the United States Supreme Court dealt with a dispute over land ownership in Oklahoma. The plaintiff, Adams, claimed that he had purchased certain lands from Native Americans before they were officially opened for settlement by an act of Congress and argued that his purchase should be recognized as valid. However, the defendant, Cowen, who had subsequently acquired title to these lands under federal law after they were opened for settlement disputed this claim. The court ruled in favor of Cowen stating that prior to opening up these lands for general settlement through legislation by Congress; individual purchases from Native Americans could not be considered legal or binding according to existing laws at that time which prohibited such transactions without government approval. Therefore any subsequent acquisition made under federal law would supersede previous claims based on unauthorized sales.

The dissenting opinion in the case of Adams v. Cowen, 1899, argued that the majority's decision to uphold a state law requiring railroads to provide separate but equal accommodations for black and white passengers was incorrect. The dissent contended that this ruling violated the Fourteenth Amendment’s Equal Protection Clause by endorsing racial segregation. They believed it was not possible for facilities to be both separate and equal because separation inherently implied inequality. Furthermore, they asserted that such laws were designed with discriminatory intent rather than any legitimate public interest or safety concern. Therefore, these laws should have been struck down as unconstitutional under the Fourteenth Amendment which guarantees all citizens equal protection under the law regardless of race.