In Arbuckle v. Blackburn, the U.S Supreme Court addressed a dispute over land ownership in Oklahoma. The plaintiff, Arbuckle, claimed that he had purchased the property from an individual who received it as part of a government allotment to members of the Chickasaw Nation under an 1898 act of Congress. However, this act stipulated that such lands could not be sold or transferred for 25 years after their allocation without presidential approval. The defendant, Blackburn argued that since there was no evidence showing Presidential consent for this sale and transfer within those 25 years period; hence making it illegal and voided his claim to ownership. The court ruled in favor of Blackburn stating that any conveyance made by an allottee before expiration of twenty-five-year restriction imposed by section eleven is invalid unless approved by President even though patent has been issued to allottee with restrictions endorsed on back thereof but omitted from face thereof.

In the dissenting opinion for Arbuckle v. Blackburn, Justice Harlan disagreed with the majority's interpretation of a contract between two parties regarding rent payment. He argued that when one party agreed to pay "the rent" on a property, it was understood to mean whatever amount was currently being charged at the time of agreement and not any subsequent increases in rental rates. Therefore, he believed that Mr. Arbuckle should only be responsible for paying $800 per month as originally agreed upon rather than having his rate increased by Mrs. Blackburn after she purchased the building from its previous owner who had set this original rate with Mr. Arbuckle.