In the 1890 case of Etheridge v. Sperry, the United States Supreme Court ruled on a dispute involving land ownership and inheritance laws in Michigan. The plaintiff, Etheridge, claimed that he was entitled to certain lands as an heir of his deceased wife's estate. However, the defendant Sperry argued that under Michigan law at the time of her death (1855), married women did not have separate legal rights to property; therefore she could not pass any property onto her heirs upon death. The court agreed with Sperry’s argument and held that since Mrs. Etheridge had no legal right to own or control property independently from her husband during their marriage due to existing state law at that time, she consequently had no ability to pass it on through inheritance after her death.

In the dissenting opinion for Etheridge v. Sperry, Justice Lamar disagreed with the majority's interpretation of a federal statute that allowed individuals to sue in federal court if they were denied their civil rights under state law. He argued that this statute was intended to protect against violations of constitutional rights, not statutory ones. Therefore, he believed that Mr. Etheridge should have been able to bring his case in federal court because he claimed his right to vote had been violated by a state official - an action which infringed upon his constitutionally protected civil rights. Justice Lamar also took issue with the majority's assertion that Mr. Etheridge could have sought relief through other means within the state judicial system before resorting to filing suit in federal court; arguing instead that it is unreasonable and unjustifiable burden on citizens who believe their constitutional rights are being violated by state officials. Finally, Justice Lamar expressed concern about potential implications of this ruling: limiting access to justice for those whose civil liberties may be threatened or undermined at local level and potentially allowing states more leeway in infringing upon federally-protected individual freedoms without fear of legal repercussions from higher courts.