In the case of Gilfillan v. McKee in 1895, the United States Supreme Court ruled on a dispute regarding land ownership and inheritance rights. The plaintiff, Gilfillan, claimed he was entitled to certain lands as an heir of his deceased brother who had purchased them from their father's estate. However, McKee argued that she held rightful claim to these lands through her husband who bought them at a sheriff’s sale after they were seized due to unpaid debts by the father's estate. The court found in favor of McKee stating that her husband’s purchase at a public auction gave him legal title over any potential claims by heirs or other purchasers from the original owner (the debtor). This ruling affirmed that property sold under execution cannot be reclaimed by those claiming under conveyances made subsequent to judgment but prior to sale.

In the dissenting opinion for Gilfillan v. McKee, Justice Brewer argued against the majority's decision to deny jurisdiction over a dispute involving church property. He contended that while ecclesiastical matters should be left to religious bodies, civil courts still have an obligation to resolve disputes about property rights and contracts within these organizations. In his view, it was not only appropriate but necessary for secular courts to intervene in such cases when internal resolution mechanisms failed or were non-existent. He further disagreed with the majority's assertion that this case involved doctrinal issues rather than legal ones; he saw it as purely a matter of contract law and thus well within their purview.