In the 1918 case of Coon v. Kennedy, the United States Supreme Court addressed a dispute over land ownership in Oregon. The plaintiff, Coon, claimed that he had purchased property from an individual who obtained it through the Donation Land Claim Act of 1850 - legislation which granted free land to settlers in Oregon Territory. However, defendant Kennedy argued that this was not valid as the original owner did not fulfill residency requirements outlined by said act and thus never legally owned it. The court ruled in favor of Kennedy stating that under federal law at that time (the Donation Land Claim Act), one must reside on and cultivate their claim for four consecutive years to gain legal title to such lands; failing these conditions would result in forfeiture back to government possession. Since there was no evidence proving compliance with these terms by initial claimant before selling his rights off to others including Coon's predecessor-in-interest, they held all subsequent transfers void too.

In the dissenting opinion for Coon v. Kennedy, it was argued that the majority's decision to uphold a state law prohibiting non-residents from hunting or fishing without a guide violated the Privileges and Immunities Clause of Article IV, Section 2 of the U.S. Constitution. The dissenting justices believed that this clause guarantees citizens in each state equal access to all privileges and immunities enjoyed by citizens in other states, including hunting and fishing rights. They contended that while states have authority over their natural resources, they cannot discriminate against out-of-state residents regarding these resources' use under normal circumstances. Therefore, requiring non-residents to hire guides as a condition for exercising such rights constituted unjust discrimination according to them.