In the 1900 case of Holly v. Missionary Society of the Protestant Episcopal Church, the U.S. Supreme Court dealt with a dispute over land ownership in Alaska. The plaintiff, Holly, claimed that he had purchased a piece of property from an Alaskan native who held rightful title to it under Russian law before Alaska was sold to the United States in 1867. He argued that this title should be recognized by American courts and thus contested the defendant's claim to own said property through purchase from another party after 1867. The court ruled against Holly, stating that at no point did Russia recognize individual native claims to land; rather all lands were owned collectively by tribes or clans and governed according to their customs. Therefore, any sale made by an individual without consent from his tribe would not have been valid even under Russian rule. Furthermore, when America bought Alaska they acquired "absolute fee" (complete ownership) which extinguished any previous rights unless specifically reserved in treaty - something not done here as natives weren't parties involved in negotiations between Russia and US government.

The dissenting opinion in the case of Holly v. Missionary Society of the Protestant Episcopal Church argued that the plaintiff, Mr. Holly, had a valid claim against the defendant for breach of contract and false representation. The justices contended that there was sufficient evidence to show that an agreement existed between both parties where Mr. Holly would be provided with financial support by the church society in return for his missionary work among African Americans in Haiti. They believed this constituted a legally binding contract which had been breached when funding was withdrawn without any justifiable cause or prior notice given to Mr. Holly as required under contractual law principles. Furthermore, they disagreed with majority's view on misrepresentation issue stating it wasn't merely about whether he could have discovered truth but rather if he relied upon their representations while making decision to move his family and establish mission in Haiti. They also expressed concern over potential implications of ruling on religious organizations' accountability towards individuals who rely on them for livelihoods arguing such entities should not be exempt from legal obligations simply due to their religious nature. In conclusion, they felt justice hadn't been served adequately because court failed to recognize validity of claims made by plaintiff thereby denying him rightful compensation for losses suffered due to defendants' actions.