In the Fuller v. United States case of 1900, Melville Weston Fuller, Chief Justice of the Supreme Court at that time, ruled on a dispute over land in Oklahoma. The plaintiff claimed that he had been unlawfully dispossessed from his property by the defendant and sought restitution for damages incurred during this period. However, it was found that when Congress passed an act to open up lands in Oklahoma for settlement in 1893, they did not intend to grant rights to individuals who were already occupying these lands prior to their official opening date unless those individuals made proper application within a specified timeframe after said date - which the plaintiff failed to do. Therefore, despite having occupied and improved upon the land before its official opening for settlement under federal law (and thus being technically considered as trespassing), because he didn't apply within sixty days after proclamation as required by law; his claim was deemed invalid and dismissed.

In the dissenting opinion for Fuller v. United States, Justice Harlan argued that the majority's ruling was a misinterpretation of both the Constitution and previous court rulings. He contended that Congress did not have unlimited power to govern territories acquired by the U.S., but rather its powers were limited by constitutional guarantees of personal rights. In his view, these limitations applied regardless of whether or not Congress had made specific provisions for local self-government in those territories. Furthermore, he disagreed with the majority's assertion that Puerto Rico was a foreign country in terms of tariff laws after it became a U.S territory post Spanish-American War; instead arguing it should be treated as part of America itself under such circumstances.