In the 1905 case of Hodges v. United States, the Supreme Court ruled on an issue related to property rights and due process. The appellant, Hodges, had purchased land in Arkansas that was previously owned by a railroad company which had received it through a grant from Congress. After selling the land to private owners like Hodges, the railroad company went bankrupt and its assets were transferred back to the government as part of bankruptcy proceedings. The government then sold these lands again without recognizing prior sales made by the railroad company. Hodges sued for his right to keep his property but lost in lower courts before appealing to Supreme Court arguing that he was denied due process under Fifth Amendment because he wasn't given notice or opportunity for hearing before losing his property. The Supreme Court upheld lower court decisions against Hodges stating that since original grant from Congress contained conditions allowing reversion of ownership back to government if certain circumstances occurred (like bankruptcy), there was no violation of due process when those conditions were met and ownership reverted back even though this affected subsequent purchasers like Hodges who weren't party to original agreement.

In the dissenting opinion for Hodges v. United States, Justice Harlan argued that the majority's interpretation of the Thirteenth Amendment was too narrow and failed to fully address its purpose: to abolish all forms of slavery and involuntary servitude. He believed that this included not only physical bondage but also any conditions which effectively reduced a person to a state similar to slavery, such as economic or social coercion. In his view, Congress had broad powers under the amendment to legislate against racial discrimination in employment practices because these could create conditions akin to involuntary servitude by limiting opportunities for African Americans. Therefore, he disagreed with the majority's decision that federal law did not protect black citizens from being denied work based on their race by private individuals or corporations.