In the Clark v. Reeder case of 1894, the U.S. Supreme Court ruled on a dispute over land ownership in Kansas. The plaintiff, Clark, claimed that he had purchased the land from an individual who had obtained it through preemption rights under federal law. However, Reeders argued that they were rightful owners as they bought it from someone who acquired it via homesteading laws after its abandonment by original preemptor before patent issuance or final proof was made to government officials for his claim. The court held that once a settler has filed a declaratory statement and complied with all requirements of preemption laws (including living upon and improving the property), their right to purchase becomes vested and can be sold or transferred even if no patent has been issued yet by government authorities; thus ruling in favor of Clark's claim.

In the dissenting opinion for Clark v. Reeder, Justice Brewer argued that the majority's decision was inconsistent with previous rulings on land ownership and inheritance rights. He contended that under Michigan law, a wife had an equal right to her husband's property upon his death if there were no direct heirs - in this case, children or grandchildren. The majority ruled that because Mr. Clark had siblings at the time of his death, Mrs. Clark did not have full rights to his property; instead it should be divided between her and Mr. Clark’s siblings equally as per intestate succession laws of Michigan state which contradicts common-law rules regarding marital property rights where surviving spouse is entitled to entire estate when deceased leaves no descendants but has collateral kindred (siblings). Justice Brewer believed this interpretation was incorrect and unfair towards Mrs.Clark who should've been granted full possession of her late husband's estate without having any obligation towards sharing it with deceased’s siblings.