In the 1912 case of Camp v. Boyd, the United States Supreme Court dealt with a dispute over land ownership in Georgia. The plaintiff, Camp, claimed that he had purchased a tract of land from an individual who had acquired it through adverse possession - essentially by occupying and using it for seven years without challenge from its legal owner. However, this claim was disputed by Boyd on behalf of his late father's estate which held the original title to the property. The court ruled against Camp stating that under Georgia law at least twenty years of unchallenged occupation were required to establish ownership through adverse possession if there is no "color of title" or some form of document purporting to convey title such as a deed or will. Since neither condition was met in this case, they concluded that Boyd's father remained the rightful owner throughout and thus his heirs retained valid claim to it after his death.

In the dissenting opinion for the case of CAMP v. BOYD, Justice Holmes disagreed with the majority's decision to uphold a lower court ruling that denied Camp his claim on certain lands in Alaska. He argued that Camp had established sufficient residence and improvement on these lands as required by law to stake a valid claim. The justice contended that while there may have been some irregularities in how Camp went about staking his claim, they were not significant enough to invalidate it entirely. Furthermore, he believed that Boyd did not have any stronger or more legitimate claims over this land than Camp did. Therefore, he concluded that denying Camp's claim was unjust and inconsistent with existing laws regarding property rights and land ownership.