In the case of Gallup v. Schmidt in 1901, the Supreme Court dealt with a dispute over land ownership. The plaintiff, Gallup, claimed that he had purchased a piece of property from an individual who had acquired it through inheritance. However, the defendant, Schmidt argued that this was not possible because under German law (the deceased owner was German), real estate could only be passed on to direct descendants and not to other relatives or third parties without explicit will or testamentary provision stating otherwise. The court ruled in favor of Schmidt after determining that according to international law principles at play during this time period - specifically those related to conflict-of-laws rules - they were bound by Germany's laws regarding inheritance since the original owner died there while still holding citizenship status despite living most his life in America where he also held citizenship status as well.

In the dissenting opinion for Gallup v. Schmidt, it was argued that the majority's decision to uphold a state law allowing creditors to seize debtor property without prior notice or hearing violated due process rights under the Fourteenth Amendment. The dissent emphasized that such laws could lead to abuses and injustices as they give too much power and discretion to creditors at the expense of debtors' constitutional rights. They contended that even if a debtor owes money, they still have a right to be heard in court before their property is seized. This fundamental principle of fairness should not be compromised by any state law designed solely for expediency in collecting debts.