In the 1890 Supreme Court case Carpenter v. Strange, the dispute centered around land ownership and inheritance laws in California. The plaintiff, Carpenter, claimed that he was entitled to a parcel of land based on an agreement with his deceased brother's wife. However, under Californian law at the time, a widow had no authority to sell her late husband's property without court approval or consent from all heirs involved. The defendant argued that since these conditions were not met when she agreed to sell the land to Carpenter, their agreement was invalid and unenforceable by law. The Supreme Court ruled in favor of Strange (the defendant), stating that any contract made between him and Mrs.Carpenter (the plaintiff) regarding her late husband’s estate is void unless it has been approved by a probate court or if all parties who have interest in said estate give their consent for such transaction.

In the dissenting opinion for Carpenter v. Strange, Justice Field disagreed with the majority's decision to uphold Alabama's statute that allowed a widow to retain her deceased husband's property if she had children, even if there were outstanding debts owed by his estate. He argued that this law violated the Fourteenth Amendment’s Equal Protection Clause because it discriminated against creditors based on their marital and parental status. Furthermore, he contended that such laws could lead to abuse as debtors might marry and have children simply to protect their assets from being seized for debt repayment. He believed that all citizens should be treated equally under the law regardless of their personal circumstances or relationships.