In Greeley v. Lowe (1894), the U.S. Supreme Court dealt with a dispute over land ownership in Washington D.C., which involved conflicting claims based on different types of legal documents - one being a patent from the United States and another, an older deed from private individuals. The plaintiff, Greeley, claimed title to certain lands under patents issued by the United States while defendant Lowe asserted his right through deeds predating those patents. The court ruled that when there is a conflict between these two forms of evidence for land ownership, priority should be given to the older document if it can be proven valid and effective at its date of issue. Therefore, despite having later-issued federal patents as proof of ownership, Greeley's claim was rejected because Lowe could show that he had valid deeds predating those patents.

In the dissenting opinion for Greeley v. Lowe, Justice Brewer argued that the majority's decision to uphold a tax on stock dividends was incorrect. He contended that such a tax is not an income tax but rather a direct tax on property and therefore unconstitutional unless apportioned among states according to their population as required by Article I, Section 9 of the Constitution. The justice further asserted that this ruling would open up all forms of wealth and investment to similar taxation without regard for constitutional limitations or protections against unequal taxation. He warned it could lead to serious economic consequences if left unchecked.