In Halsell v. Renfrow, the U.S. Supreme Court ruled on a dispute over land ownership in Oklahoma Territory. The plaintiff, Halsell, claimed that he had purchased the land from an individual who received it as part of a government allotment to members of the Chickasaw Nation under an 1893 act of Congress. However, this act stipulated that such lands could not be sold or transferred for 25 years after their allocation without presidential approval - which was not obtained in this case. The defendant, Renfrow (who later bought the same piece of land), argued that because there was no presidential approval for Halsell's purchase and because another law passed by Congress in 1902 removed restrictions on sales only prospectively and did not validate prior unauthorized transactions; his claim to ownership should stand. The court agreed with Renfrow’s argument stating that if Congress intended to retroactively validate previous transfers made without Presidential consent they would have explicitly stated so within legislation but they did not do so here. Therefore, any sale or transfer made before enactment remained invalid unless approved by President.

In the dissenting opinion for Halsell v. Renfrow, Justice Harlan argued that the majority's decision was a departure from established principles of law and equity. He contended that it was unjust to allow one party to benefit at another's expense due to an error in legal proceedings. In this case, he believed that Halsell had been unfairly disadvantaged by a mistake made during his original trial concerning land ownership rights against Renfrow. The lower court had mistakenly ruled in favor of Renfrow based on incorrect information about property boundaries; however, when new evidence emerged showing this error, the Supreme Court refused to correct it because too much time had passed since the initial ruling - which Harlan saw as fundamentally unfair and contrary to principles of justice and fairness underpinning American jurisprudence.