In the case of Barnett et al. v. Kunkel et al., 1923, the Supreme Court dealt with a dispute over land ownership in New Mexico. The plaintiffs, Barnett and others, claimed that they had purchased the disputed property from its original owners before it was sold to Kunkel and his associates by a court-appointed receiver during bankruptcy proceedings related to an unrelated lawsuit against those original owners. The lower courts ruled in favor of Kunkel on grounds that he was a bona fide purchaser without notice of any adverse claims when he bought from the receiver. The Supreme Court reversed this decision stating that receivership did not extinguish prior legitimate claims to property if those claimants were not party to or aware of said receivership proceedings at time of purchase; thus making them "innocent purchasers". Therefore, since Barnett's group could prove their purchase predated both knowledge and occurrence of receivership sale involving same property - they should be recognized as rightful owners instead.

In the dissenting opinion for Barnett et al. v. Kunkel et al., Justice Holmes argued that the majority's decision to invalidate a Pennsylvania law regulating coal mining was incorrect and overstepped its bounds. He believed that it was not within the Court's jurisdiction to determine whether or not such laws were necessary, as this should be left up to state legislatures who are more familiar with local conditions and needs. Furthermore, he disagreed with the majority's interpretation of due process rights under the Fourteenth Amendment, arguing that these rights do not prevent states from enacting regulations in order to protect public interests like health and safety. In his view, if a law does not violate any specific constitutional prohibitions then it should be upheld as long as there is some reasonable basis for believing it serves a legitimate purpose.