In the case of Guthrie v. Harkness in 1905, the United States Supreme Court ruled on a dispute involving land ownership in Florida. The plaintiff, Guthrie, claimed that he had purchased land from the state of Florida which was later sold by the state to another party (Harkness). He argued that his purchase should be recognized as valid and sought to prevent Harkness from taking possession of it. However, when examining this claim, it was found that at no point did Guthrie have legal title or actual possession over said property; instead he merely held an agreement for deed with conditions precedent yet unfulfilled. Therefore, since there were no rights vested under such contract until performance by him of all stipulated terms and conditions precedent thereto - which never occurred - his claim could not stand against subsequent purchasers who acquired full legal title from State authorities without notice about any prior agreements made between them and previous potential buyers like himself.

In the dissenting opinion for Guthrie v. Harkness, it was argued that the majority's decision to uphold a Florida statute allowing nonresidents to be served legal notice through publication in a newspaper violated due process rights under the Fourteenth Amendment. The dissenting justices believed that this method of notification did not provide sufficient assurance that nonresident defendants would actually receive notice and have an opportunity to defend themselves in court. They contended that such indirect methods of service should only be used as a last resort when more direct methods are unfeasible or have been unsuccessful. By upholding this law, they feared the Court was setting a dangerous precedent which could undermine fundamental principles of fairness and justice inherent in American jurisprudence.