In the 1905 case of Clark v. Roller, the United States Supreme Court dealt with a dispute over land ownership in Washington D.C. The plaintiff, Clark, claimed that he had purchased a piece of property from Roller's wife after her husband's death and was now being denied access to it by Roller himself who had returned unexpectedly. The court ruled in favor of Clark stating that since Mrs. Roller sold the property believing she was indeed a widow and acted in good faith without any fraudulent intent or misrepresentation on her part; therefore, Mr. Clark’s title to the land should be upheld as valid despite Mr.Roller’s unexpected return.

In the dissenting opinion for Clark v. Roller, 1905, Justice Harlan disagreed with the majority's decision to dismiss a writ of error on jurisdictional grounds. He argued that this case involved substantial federal questions and thus should be within the Supreme Court's purview. The dispute centered around whether certain lands in Washington were part of an Indian reservation or public lands open for settlement under U.S laws. Justice Harlan believed that these issues raised significant constitutional questions about treaty interpretation and federal power over Indian affairs which warranted review by the highest court in land. Furthermore, he contended that dismissing this case would leave unresolved legal uncertainties affecting property rights and potentially exacerbating conflicts between settlers and Native Americans.