In the case of Bodkin v. Edwards (1920), the United States Supreme Court dealt with a dispute over land ownership in Virginia. The plaintiff, Bodkin, claimed that he had purchased a piece of property from an individual who was not legally able to sell it because they were not the rightful owner. Instead, this person had obtained possession through adverse possession - occupying and using someone else's property without their permission for a certain period of time until they become its legal owner under state law. However, according to Virginia law at that time, one could only gain title by adverse possession if they occupied and used the property openly and notoriously for 20 years or more. The defendant argued that since his family had been living on this land continuously since before 1866 (more than 20 years prior to when this lawsuit was filed), he should be considered its lawful owner based on adverse possession rules. However, upon reviewing evidence presented during trial proceedings including deeds dating back to early nineteenth century showing continuous chain of title in favor of plaintiff’s predecessors-in-interests till date; court ruled against defendant’s claim stating no sufficient proof has been provided demonstrating uninterrupted hostile occupation as required by statute.

The dissenting opinion in the case of Bodkin v. Edwards argued that the majority's decision was inconsistent with previous rulings and infringed upon states' rights to regulate their own affairs. The dissenters believed that the state of Virginia had a legitimate interest in regulating its oyster beds, as they were an important natural resource for the state. They also pointed out that there was no evidence to suggest any discriminatory intent or effect from Virginia's regulations, which required non-residents to pay higher fees than residents for harvesting oysters. Therefore, they did not believe these regulations violated the Privileges and Immunities Clause of Article IV or Equal Protection Clause of Fourteenth Amendment as claimed by plaintiff Bodkin who was a Maryland resident but owned land in Virginia where he wanted to harvest oysters without paying non-resident fee.