In the case of De Bearn v. Safe Deposit and Trust Company of Baltimore, 1913, the U.S Supreme Court ruled on a dispute involving inheritance law. The plaintiff was an heir to a large estate left by his father who had died in France but held property in Maryland. According to French law, all children are entitled to equal shares of their parents' estates upon death; however, under Maryland law where the property was located, it could be willed freely without regard for equality among heirs. The plaintiff argued that French laws should apply as his father was domiciled there at time of death while defendant maintained that local (Maryland) laws should govern disposition of properties within its jurisdiction. Ultimately, the court sided with defendant ruling that matters concerning real estate fall under lex rei sitae principle - meaning "the law where the property is situated" applies - thus upholding validity of will executed according to Maryland's legal provisions.

In the dissenting opinion for De Bearn v. Safe Deposit and Trust Company of Baltimore, Justice Holmes argued that the majority's decision was based on a misinterpretation of Maryland law. He contended that under Maryland law, the trust in question should be considered valid because it did not violate any rules against perpetuities or restraints on alienation. Furthermore, he disagreed with the majority's view that French law should govern this case as he believed it to be irrelevant due to its inconsistency with American legal principles and traditions. In his view, applying foreign laws would lead to confusion and uncertainty in property rights which is contrary to public policy objectives aimed at ensuring stability and predictability in such matters.