In the 1914 case of John II Estate, Limited v. Brown, the U.S. Supreme Court dealt with a dispute over land ownership in Hawaii. The plaintiff, John II Estate Limited claimed that they had rightful ownership to certain lands based on a royal patent granted by Kamehameha III in 1852. However, the defendant Brown argued that he held title to these lands due to adverse possession - essentially claiming that because he and his predecessors had openly occupied and used this land without challenge for many years (since 1879), it should now legally belong to them under Hawaiian law. The Supreme Court ruled against John II Estate Limited stating that even though they could trace their claim back to an original grant from Kamehameha III, they failed to act upon or assert their rights for such an extended period of time which allowed Brown's family uninterrupted use of the property for more than twenty years thereby establishing their own legal claim through adverse possession.

The dissenting opinion in the case of JOHN II ESTATE, LIMITED v. BROWN argued that the majority's decision to uphold a tax imposed on an estate was incorrect. The dissenting justices believed that the tax violated constitutional principles because it was not apportioned among states according to their populations as required by Article I, Section 9 of the Constitution for direct taxes. They also contended that this type of taxation could lead to abuse and inequality since Congress could potentially impose heavy burdens on certain types of property or individuals while exempting others completely from taxation. Furthermore, they disagreed with the majority's interpretation of previous court decisions related to inheritance and estate taxes, arguing these cases did not establish a precedent for upholding unapportioned direct taxes like those at issue here.