In the 1913 case Dale v. Pattison, the U.S Supreme Court dealt with a dispute over land ownership in Oklahoma. The plaintiff, Dale, claimed that he had purchased the land from an individual who had received it as part of an allotment under federal law providing for distribution of tribal lands to individual Native Americans. However, this sale was made before restrictions on alienation (transfer) were removed by Congress and thus violated federal law at that time which prohibited such sales without approval from Secretary of Interior. The defendant argued that because this initial sale was illegal, subsequent transfers including Dale's purchase were also invalid. The Supreme Court ruled in favor of Pattison stating that since the original transfer violated federal law and did not have required government approval; all subsequent transfers including one to Dale were voided too. Therefore, title remained with original owner or his heirs unless they took steps to ratify transactions after removal of restrictions on alienation.

In the dissenting opinion for Dale v. Pattison, Justice Holmes argued that the majority's decision to uphold a state law prohibiting non-residents from fishing in its waters was inconsistent with previous rulings on similar issues and violated principles of equal protection under the Fourteenth Amendment. He contended that while states have broad powers to regulate natural resources within their borders, they cannot discriminate against citizens of other states without sufficient justification. In this case, he saw no compelling reason why New York should be allowed to exclude non-residents from its fisheries while allowing them access to other public resources like roads or parks. Furthermore, he pointed out inconsistencies in how such laws were applied - noting that some residents could also be denied access if they did not meet certain criteria (like owning property). Overall, his dissent emphasized a need for fairness and equality in resource allocation across state lines.