In the case of Hayes v. Pratt, 1892, the United States Supreme Court ruled on a dispute involving land ownership in Kansas. The plaintiff, Hayes, had purchased land from an individual who had obtained it through a patent issued by the U.S government under Congressional legislation known as "the Scrip Act". However, another party named Pratt claimed to have bought this same piece of land at a tax sale after it was allegedly forfeited for non-payment of taxes. The court held that since there was no evidence showing that any notice about unpaid taxes or impending forfeiture had been given to either the original owner or his heirs before selling off his property for tax recovery purposes; such sale could not be considered valid and binding upon them. Therefore, Hayes' title derived from federal patent remained superior over Pratt's claim based on local tax-sale purchase and thus he retained rightful ownership over said parcel of land.

In the dissenting opinion for Hayes v. Pratt, it was argued that the majority's decision to uphold a tax on out-of-state insurance companies doing business in Kansas contradicted previous rulings by the Court. The dissent contended that this tax constituted an unconstitutional burden on interstate commerce and violated principles of equal protection under law as established by the Fourteenth Amendment. It was also pointed out that such taxes could lead to retaliatory measures from other states, creating a hostile environment for businesses operating across state lines. Furthermore, it was suggested that if every state imposed similar taxes, it would effectively destroy national corporations' ability to conduct business freely throughout the country - something which is contrary to federal policy and detrimental to economic growth.