In the 1919 case of Calhoun v. Massie, the United States Supreme Court addressed a dispute over land ownership in Alaska. The plaintiff, Calhoun, claimed that he had purchased Alaskan lands from an individual who had received them through a federal grant under the Coal Lands Act of 1904. However, defendant Massie argued that this transaction was invalid because it violated provisions within the Act which prohibited sales to non-U.S citizens (Calhoun being Canadian). The lower court ruled in favor of Massie and declared him rightful owner of these lands. Upon appeal to the Supreme Court though, this decision was reversed. While acknowledging restrictions on foreign ownership present in other parts of U.S law at that time (such as those concerning public lands), Justice Mahlon Pitney noted no such restriction existed within text or intent behind Coal Lands Act itself - thus making its application here inappropriate and unjustified. The ruling clarified interpretation around this legislation while also reinforcing principles related to property rights and contractual freedom; ultimately recognizing Calhoun's claim as valid despite his nationality.

In the dissenting opinion for Calhoun v. Massie, it was argued that the majority's decision to uphold a lower court ruling in favor of Massie violated Calhoun's constitutional rights. The dissenting justices believed that by allowing a state law to supersede federal bankruptcy laws, the Court had overstepped its bounds and infringed upon Congress' exclusive power to establish uniform bankruptcy laws throughout the country. They contended that this case represented an instance where state law should not be allowed to interfere with or obstruct federal legislation, as doing so would undermine national sovereignty and disrupt interstate commerce. Furthermore, they asserted that if states were permitted such interference in matters of bankruptcy proceedings, it could lead to inconsistent rulings across different jurisdictions which would ultimately defeat the purpose of having a unified national system for handling bankruptcies.