In the De La Rama v. De La Rama case of 1905, the U.S Supreme Court was tasked with resolving a dispute over property ownership between two family members. The plaintiff, Maria de la Rama y Rodriguez, claimed that she had been defrauded by her brother-in-law and co-defendant Gregorio de la Rama out of her share in their joint business venture - a sugar plantation in Negros Occidental, Philippines. She argued that Gregorio had manipulated financial records to make it appear as though he owned more shares than he actually did. However, the court ruled against Maria on grounds that she failed to provide sufficient evidence supporting her claims of fraud and misrepresentation by Gregorio. Furthermore, they found no legal basis for altering the distribution of shares agreed upon during their partnership's formation.

In the dissenting opinion for De La Rama v. De La Rama, Justice Harlan disagreed with the majority's decision to dismiss the case on jurisdictional grounds. He argued that there was a valid basis for federal jurisdiction because of diversity of citizenship between parties and an amount in controversy exceeding $2,000 - both requirements under Article III of the Constitution. Furthermore, he contended that it was not necessary for all defendants to be diverse from all plaintiffs as long as there is at least one plaintiff who is diverse from at least one defendant. In his view, dismissing this case would create a precedent where litigants could manipulate their lawsuits by adding non-diverse parties just to defeat federal jurisdiction which goes against principles of fairness and justice.