In the 1903 case of Eaton v. Brown, the United States Supreme Court ruled on a dispute involving land ownership and inheritance rights. The plaintiff, Eaton, claimed that he was entitled to certain lands in California based on an inheritance from his deceased brother who had acquired these lands under Mexican law prior to California becoming part of the U.S. However, defendant Brown argued that because Eaton's brother died intestate (without a will), according to Californian succession laws at that time which did not recognize siblings as legal heirs if parents were still alive when their child died without issue or spouse, Eaton had no claim over those properties. The court sided with Brown stating that upon admission of California into Union in 1850 all its existing laws became subject to alteration by Congress and could be superseded by state legislation unless they conflicted with federal constitution or acts of congress. Therefore it upheld application of Californian succession law denying any right for siblings if parents survived their child dying intestate even though such provision didn't exist under Mexican law previously governing those territories.

In the dissenting opinion for Eaton v. Brown, Justice Harlan disagreed with the majority's ruling that a state law requiring railroad companies to provide separate but equal accommodations for black and white passengers did not violate the Fourteenth Amendment. He argued that such laws were inherently unequal because they were based on racial prejudice rather than any real differences between races. He also pointed out that these laws effectively stigmatized black people as inferior, which he believed was contrary to the principles of equality enshrined in the Constitution. Furthermore, he contended that it was not within a state's power to enforce segregation in private businesses like railroads, since this would infringe upon individuals' rights to contract freely under their own terms without government interference.