In the 1892 case of Curtner v. United States, the Supreme Court dealt with a dispute over land ownership in Arkansas. The appellant, Curtner, claimed that he had purchased the disputed land from its original owners who received it through a grant by Spain before it became part of U.S territory. However, upon investigation, no evidence was found to support this claim and instead showed that the land was public domain at all relevant times under U.S control. The court ruled against Curtner stating that his title claims were invalid as they lacked substantial proof or documentation to establish their legitimacy and authenticity beyond reasonable doubt.

In the dissenting opinion for Curtner v. United States, Justice Brewer argued that the majority's decision was a misinterpretation of the law and an overreach of federal power. He contended that while Congress has broad powers to regulate interstate commerce, it does not have unlimited authority to control all aspects of business operations within individual states. In this case, he believed that regulating livestock prices at local auctions fell outside the scope of interstate commerce regulation because these transactions were essentially intrastate activities with only indirect effects on interstate trade. Therefore, in his view, they should be left under state jurisdiction rather than being subject to federal oversight and penalties as per Sherman Antitrust Act provisions applied by majority ruling.