In the 1917 case of Aikins v. Kingsbury, the U.S Supreme Court dealt with a dispute over land ownership in Michigan. The plaintiff, Aikins, claimed that he had purchased certain lands from the state under swamp-land laws and was entitled to their possession. However, Kingsbury (the defendant), as Register of the State Land Office, argued that these lands were not subject to purchase because they had been reserved for public use by an act of Congress prior to Michigan's admission into Union. The court ruled in favor of Kingsbury stating that when Michigan was admitted into Union it accepted all terms and conditions set forth by Congress which included reserving certain lands for common schools or other public uses. Therefore, those specific parcels could not have been sold under any circumstances including swamp-land laws.

The dissenting opinion in the case of Aikins v. Kingsbury, as Register of the State Land Office (1917), argued that the majority's decision was inconsistent with previous rulings and interpretations of relevant laws. The dissenting justices believed that a strict interpretation of Michigan’s swamp land act should not have allowed for private individuals to purchase public lands designated as “swamp” or “overflowed.” They contended that these lands were intended for public use and improvement, rather than private ownership. Furthermore, they disagreed with the majority's view on whether Aikins had established a valid claim to the disputed property prior to its designation as swamp land by state authorities. In their view, his failure to properly register his claim invalidated any rights he might otherwise have had under federal law.