In the Hartranft v. Meyer case of 1892, the U.S. Supreme Court ruled in favor of John F. Hartranft, Superintendent of the Eastern State Penitentiary in Philadelphia, against an inmate named Meyer who was serving a life sentence for murder and claimed his constitutional rights were violated by being kept in solitary confinement without any form of employment or instruction. The court held that while prisoners do have certain basic rights under the Constitution, these do not include a right to work or receive education while incarcerated. They also found no evidence that solitary confinement constituted cruel and unusual punishment as prohibited by Eighth Amendment since it was within acceptable penal practices at that time.

In the dissenting opinion for Hartranft v. Meyer, Justice Brewer argued that the majority's decision to uphold Pennsylvania's escheat law was incorrect because it violated due process rights under the Fourteenth Amendment. He contended that a state could not simply declare ownership of unclaimed property without first making an effort to locate and notify potential owners or heirs. In his view, this amounted to taking private property without just compensation or due process of law. Furthermore, he disagreed with the majority's interpretation of what constituted "abandonment" in relation to unclaimed assets held by banks and other institutions; he believed such assets should not be considered abandoned unless there is clear evidence that their owner intended them as such.