In De Cambra v. Rogers, 1902, the U.S Supreme Court was tasked with deciding on a dispute over land ownership in Hawaii. The plaintiff, De Cambra claimed that he had purchased the land from Kekauonohi and Kealiiahonui who were descendants of former Hawaiian royalty and therefore rightful owners of the property. However, defendant Rogers argued that under an 1848 law known as "the Great Mahele," which redistributed Hawaiian lands among its monarchy, government and commoners; only King Kamehameha III could sell or give away crown lands after they had been divided up by this act. Therefore any sale made by his descendants would be invalid since they did not have legal rights to do so. The court ruled in favor of Rogers stating that according to “the Great Mahele,” it was clear that once these lands became part of public domain under control of monarchs like King Kamehameha III; their heirs lost all claims over them unless specifically mentioned otherwise in their wills or other legal documents which wasn't case here hence making De Cambra's purchase null & void.

In the dissenting opinion for De Cambra v. Rogers, Justice Harlan disagreed with the majority's decision to uphold a lower court ruling that denied an inheritance claim by Portuguese citizens on property in California. He argued that under international law and treaties between Portugal and the United States, these individuals should have been allowed to inherit their relative's estate despite not being U.S. residents or citizens at the time of his death. The justice contended that denying them this right was discriminatory and violated principles of equity and fairness as well as established legal precedents regarding foreign nationals' rights to inherit property in America.