In the 1907 case of Battle v. United States, the Supreme Court ruled on an issue related to land ownership and inheritance laws. The dispute arose after a Creek Indian woman named Eliza Battle died intestate (without a will), leaving behind several parcels of allotted land in Oklahoma. Her husband, William C. Battle, claimed that he was entitled to inherit all her property as per state law at that time which allowed husbands full rights over their wives' estates if they died without a will or children. However, this claim was contested by Eliza's siblings who argued that under federal law - specifically the Dawes Act of 1887 and its amendments - they were entitled to share in her estate equally with Mr.Battle because these laws provided for equal distribution among heirs regardless of gender or marital status. The Supreme Court sided with Mr.Battle ruling that while federal legislation did indeed govern allotment and disposal of lands within Indian territories; it did not supersede state probate laws when it came to determining succession rights once those lands had been allotted out individually. Therefore, since Mrs.Battle’s property fell into this category at the time she passed away; Oklahoma’s probate rules applied making her husband sole heir.

In the dissenting opinion for Battle v. United States, Justice Harlan argued that the majority's decision was inconsistent with previous rulings of the Court and violated principles of justice. He contended that a defendant should not be held criminally liable if they were unaware of their illegal actions at the time they were committed, as in this case where Mr. Battle had unknowingly passed counterfeit money. According to Justice Harlan, ignorance or mistake about facts which would show non-violation of law is always a defense to criminal charges because it negates wrongful intent - an essential element in every crime unless specifically excluded by statute. Therefore, he believed that Mr. Battle should have been allowed to present evidence showing his lack of knowledge about counterfeiting nature of notes he circulated and jury should have been instructed accordingly before deciding on his guilt or innocence.