In the 1900 case of Baggs v. Martin, the United States Supreme Court dealt with a dispute over land ownership in Florida. The plaintiff, Baggs, claimed that he had purchased the property from an individual who had received it as part of a Spanish land grant before Florida became part of the U.S., and thus his claim was superior to any subsequent American claims on this territory. However, defendant Martin argued that he held title to this same parcel through purchase from another party after Florida's incorporation into America. The court ruled in favor of Martin based on evidence showing that at no point did Spain officially recognize or confirm such grants made during its rule over Florida prior to ceding control to America in 1821; therefore these alleged grants could not be considered valid against later American titles under U.S law.

The dissenting opinion in the case of Baggs v. Martin argued that the majority's decision to uphold a state law prohibiting non-residents from hunting game for commercial purposes was inconsistent with previous rulings on similar cases and violated principles of equal protection under the Fourteenth Amendment. The dissent contended that there was no legitimate state interest served by discriminating against non-residents, as both residents and non-residents could equally contribute to overhunting or other potential harms associated with commercial hunting. Furthermore, they asserted that this discriminatory treatment created an unjustifiable burden on interstate commerce by preventing out-of-state hunters from participating in a lucrative industry within the state's borders. Thus, they believed such laws should be struck down as unconstitutional rather than upheld.