In the 1917 case of Cissna v. State of Tennessee, the U.S. Supreme Court ruled on a dispute involving land ownership and mineral rights in Tennessee. The plaintiff, Cissna, was an heir to a large tract of land rich in coal and timber resources which had been sold by his ancestors under allegedly fraudulent circumstances to English investors who later formed the Bon Air Coal & Iron Corporation. He sought to reclaim this property arguing that it should never have been sold due to legal restrictions on alien ownership of land at that time. The court however rejected his claim stating that while there were indeed laws restricting foreign individuals from owning property in Tennessee during the late 19th century when the sale occurred, these did not apply to corporations even if they were controlled by foreigners as was Bon Air Coal & Iron Corporation. Furthermore, it held that since those laws had subsequently been repealed without any provision for retroactive application or restitution for past sales deemed illegal under them; their repeal effectively legitimized all such previous transactions thereby extinguishing any claims arising from them including Cissna's.

In the dissenting opinion for CISSNA v. STATE OF TENNESSEE, the justice argued that Cissna's constitutional rights were violated due to his inability to present a defense in court. The justice believed that Cissna was not given an adequate opportunity to defend himself against charges of violating Tennessee’s prohibition laws because he was denied access to legal counsel and did not have sufficient time or means to prepare his case. Furthermore, it was highlighted that there were procedural errors during trial which further compromised Cissna's right to a fair hearing. Therefore, according to this dissenting view, the conviction should be overturned on grounds of these constitutional violations.