In the case of United States ex rel. Holzendorf v. Hay, 1903, the U.S Supreme Court dealt with a dispute over land ownership in Florida. The plaintiff, Holzendorf claimed that he had purchased a large tract of land from the state of Florida which was subsequently sold by the federal government to another party (Hay). He argued that this sale was invalid as it violated his rights under an earlier Congressional Act granting certain lands to Florida for public purposes and thus could not be sold by Federal Government without violating his property rights. However, after examining all relevant legislation and facts surrounding both sales, including whether or not Holzendorf's purchase from State of Florida included these specific lands in question or if they were part of federally owned territory at time when Congress granted them to state for public use; court ruled against him stating that there is no evidence supporting his claim about violation on property rights due to second sale made by Federal Government.

In the dissenting opinion for the United States ex rel. Holzendorf v. Hay case, it was argued that there should be a distinction between cases where an individual is seeking to avoid extradition due to fear of persecution based on their political beliefs and those where they are simply trying to escape justice for crimes committed. The dissenting justices believed that in this particular case, Holzendorf's claim of potential political persecution if returned to Russia did not hold enough weight against his alleged criminal activities which included forgery. They contended that allowing him asylum would set a dangerous precedent whereby any criminal could potentially evade justice by claiming political persecution in their home country.