In the case of Campbell v. United States in 1924, the Supreme Court ruled on an issue related to tax law and property rights. The plaintiff, Campbell, had purchased land from a railroad company that was granted by Congress under the Pacific Railroad Acts during the mid-19th century. After selling timber from this land, he did not include it as income for his federal taxes because he believed it fell under capital gains rather than ordinary income due to its classification as real estate property. However, the Internal Revenue Service (IRS) disagreed with this interpretation and claimed back taxes were owed. The Supreme Court sided with Campbell's argument that proceeds from timber sales should be treated as capital gains instead of regular income since they derived from real estate assets acquired through purchase. This ruling clarified how profits made off natural resources found on one's own property are taxed at a lower rate compared to other types of earnings.

In the dissenting opinion for Campbell v. United States, it was argued that the court majority erred in its interpretation of the Volstead Act and its application to this case. The dissenting justices believed that Congress did not intend to criminalize all possession of liquor under any circumstance but rather intended only to penalize illegal manufacturing, selling, or transporting alcohol during Prohibition. They contended that personal use or possession should not be considered a crime unless there is clear evidence linking it with an intent to violate prohibition laws such as by selling or distributing alcohol illegally. In their view, mere ownership of alcoholic beverages does not necessarily imply an intention to break these laws; therefore they disagreed with the decision convicting Campbell merely on grounds of possessing liquor without proof he planned any unlawful actions involving his stockpile.