In the case of Hale v. Lewis in 1900, the U.S. Supreme Court addressed a dispute over land ownership and inheritance laws in Utah Territory. The plaintiff, Mrs. Hale, claimed that she was entitled to one-half of her late husband's estate based on territorial statutes regarding community property rights at the time of their marriage in 1861. However, Mr. Lewis argued that these statutes were superseded by federal legislation enacted after their wedding but before Mr.Hale's death which granted wives only a one-third interest in their husbands' estates upon death without a will (intestate). The court ruled against Mrs.Hale stating that although community property rights existed when they married, those rights did not vest until her husband’s death; therefore his estate would be distributed according to the law at his time of passing rather than at their marriage date.

The dissenting opinion in the case of Hale v. Lewis argued that the majority's decision to uphold a state law prohibiting interracial marriage was fundamentally flawed and inconsistent with constitutional principles. The dissenting justices contended that such laws were inherently discriminatory, violating both equal protection and due process clauses of the Fourteenth Amendment. They maintained that marriage is a fundamental right, central to personal autonomy and dignity, which should not be restricted based on racial classifications. Furthermore, they asserted that these laws served no legitimate governmental interest but rather perpetuated notions of racial superiority and inferiority. Thus, they believed this ruling contradicted previous decisions affirming individual rights against arbitrary government interference.