In the 1893 case Ashley v. Ryan, the U.S Supreme Court dealt with a dispute over land ownership in California. The plaintiff, Ashley, claimed that he had purchased the property from an individual who obtained it through a Mexican land grant before California became part of the United States. However, this claim was disputed by Ryan on grounds that there were inconsistencies and inaccuracies in Ashley's documentation proving his right to ownership. The court ruled in favor of Ryan after determining that these discrepancies indeed existed and thus cast doubt on whether or not Ashley's predecessor truly owned the property at all. Furthermore, they found no evidence supporting claims made by Ashley about improvements made to said property which would have strengthened his case for possession rights under preemption laws.

In the dissenting opinion for Ashley v. Ryan, it was argued that the majority's decision to uphold a state law prohibiting non-residents from fishing in its waters violated the Privileges and Immunities Clause of Article IV of the Constitution. The dissenting justices believed that this clause guaranteed citizens of each state equal access to all basic rights afforded by any other state, including natural resources such as fish. They contended that while states have a right to regulate their own fisheries, they cannot discriminate against out-of-state residents who wish to partake in these public commodities. The dissenters also disagreed with the majority's view that commercial fishing could be classified differently under constitutional law than recreational fishing; they saw no reason why one should be protected under interstate commerce laws but not the other.