In the 1932 case Dalton et al. v. Bowers, Executor, the Supreme Court of the United States was tasked with determining whether a will that left property to religious organizations violated laws against perpetuities and accumulations or promoted superstition. The testator's will stipulated that his estate should be used to build and maintain a hospital for individuals suffering from cancer in memory of his wife who died from this disease; however, it also contained provisions requiring prayers for their souls as part of its operation. The executors sought instruction on these points due to concerns about potential legal issues. The court ruled that while some aspects might seem superstitious (such as praying for souls), they did not violate public policy because they were secondary elements within an overall charitable purpose - providing medical care for those afflicted by cancer. Furthermore, it held that there was no violation of rules against perpetuity or accumulation since any income generated would be immediately put towards maintaining and operating the hospital rather than being stored up indefinitely.

In the dissenting opinion for Dalton et al. v. Bowers, Executor, 1932, Justice Stone argued that the majority's decision to uphold a tax on an inheritance was incorrect because it violated constitutional protections against double taxation. He contended that the estate had already been taxed once when its assets were initially acquired and should not be subject to additional taxes upon transfer through inheritance. Furthermore, he disagreed with the majority's interpretation of "transfer" in relation to estates and inheritances; he believed this term should only apply when ownership changes hands during one's lifetime rather than after death. In his view, allowing such taxation would open up possibilities for excessive or unjust levies by states seeking revenue sources without regard for individual property rights.