In the 1904 case Bartlett v. United States, the U.S Supreme Court ruled on a dispute regarding land ownership in Alaska. The plaintiff, Bartlett, claimed that he had purchased Alaskan land from an individual who had received it as part of a military bounty land warrant under an 1855 law. However, this law did not allow for such warrants to be used for lands in territories acquired after its enactment - which included Alaska (acquired by the US in 1867). The defendant was the federal government which argued that since Alaska was acquired after the passage of this act and because there were no specific provisions allowing these warrants to be applied to newly-acquired territory post-act, Bartlett's claim was invalid. The court sided with the government stating that unless Congress explicitly provided otherwise within legislation or treaty terms when acquiring new territory; existing laws would not automatically apply there. Therefore, they held that military bounty land warrants could not be used for lands located in territories obtained by America following their respective acts' passage dates without explicit Congressional authorization – thus rendering Bartlett’s purchase void.

The dissenting opinion in Bartlett v. United States argued that the Supreme Court should not have jurisdiction over this case, as it involved a dispute between private parties rather than a constitutional issue. The dissenters believed that the majority's decision to hear the case was an overreach of their authority and set a dangerous precedent for future cases. They also disagreed with the majority's interpretation of maritime law, arguing that it did not apply in this situation because Bartlett had willingly entered into his contract with the ship owners and therefore assumed any risks associated with his employment. Finally, they expressed concern about potential negative impacts on commerce if seamen were allowed to sue their employers for injuries sustained while working aboard ships.