The U.S. Supreme Court case Earle v. Carson in 1902 revolved around a dispute over land ownership and inheritance rights, specifically involving the interpretation of wills and deeds under Alabama state law. The plaintiff, Earle, claimed that he was entitled to certain lands as an heir of his father's estate while the defendant, Carson (the executor of another relative’s estate), argued otherwise based on a different interpretation of the same documents. The court ruled in favor of Earle stating that according to Alabama laws regarding property distribution after death without specific bequests or devises, all heirs are equally entitled to their proportionate shares unless explicitly stated otherwise by the deceased person's will or deed. Therefore it was determined that Earle had rightful claim over part of his father’s land.

In the dissenting opinion for Earle v. Carson, Justice Harlan argued that the majority's decision was a misinterpretation of both the Constitution and previous Supreme Court rulings. He contended that Congress had clear authority to regulate interstate commerce under Article I, Section 8 of the Constitution and this power extended to insurance companies operating across state lines. The majority's argument that insurance contracts were not articles of commerce but rather agreements was flawed according to him because it ignored precedent set by Paul v. Virginia (1869) where it was ruled that issuing an insurance policy did constitute a commercial transaction subject to federal regulation. Furthermore, he believed allowing states exclusive control over such matters would lead to inconsistent regulations which could disrupt national economic stability.