In the 1890 U.S. Supreme Court case Briggs v. Spaulding, a dispute arose over land ownership in Michigan between two parties: one who had purchased tax-title to the property and another who claimed title under an older patent from the United States government. The court ruled that if a person purchases land at a tax sale without knowing there is an existing superior title, they are not entitled to compensation for improvements made on said land after discovering this fact. This ruling was based on principles of equity and fairness; it would be unjust for someone knowingly improving upon property with knowledge of its disputed status to then demand repayment from the rightful owner once their claim is established in law.

In the dissenting opinion for Briggs v. Spaulding, Justice Bradley argued that the Court had overstepped its bounds by interpreting state law in a manner inconsistent with decisions of the New York courts. He contended that it was not within their jurisdiction to interpret or apply state laws differently than how they were understood and applied by local courts unless there was an apparent violation of federal rights. Furthermore, he believed that this case did not involve any such violation as it pertained to a dispute about property rights under New York law rather than constitutional issues. Therefore, according to him, the Supreme Court should have deferred to local interpretation and application of state laws instead of imposing its own understanding on them.