In the 1904 case of Dunbar v. Green, the United States Supreme Court dealt with a dispute over land ownership in Arkansas. The plaintiff, Dunbar, claimed that he had purchased a piece of property from its original owner and was therefore entitled to it. However, the defendant, Green, argued that she had been living on and improving this property for several years under an agreement with another party who also claimed ownership rights to it. She contended that her long-term possession and improvement of the land gave her rightful claim to it under squatter's rights or "adverse possession." The lower court ruled in favor of Green but upon appeal by Dunbar; the Supreme Court reversed this decision stating that adverse possession could not be applied as there was no evidence showing continuous use or occupation by Green for seven consecutive years which is required under Arkansas law.

The dissenting opinion in the case of Dunbar v. Green argued that the majority's decision was inconsistent with previous rulings and failed to properly interpret relevant statutes. The dissent contended that a person who has been granted power of attorney should be allowed to act on behalf of another individual, even if they are not physically present at the time when an action is taken. They believed this principle applied regardless of whether or not it was explicitly stated in the power-of-attorney document itself. Furthermore, they disagreed with the majority's interpretation of what constitutes "presence" under law, arguing for a broader understanding that includes both physical presence and representation by proxy through legal instruments such as powers-of-attorney.