In the 1914 U.S. Supreme Court case Kapiolani Estate, Limited v. Atcherley, the court ruled on a dispute involving land ownership in Hawaii. The plaintiff, Kapiolani Estate Limited had leased land to Mr. and Mrs. Atcherley who later claimed they owned it through "adverse possession," a legal principle that allows someone to gain ownership of another's property if they have occupied it for an extended period without challenge from the original owner. However, during this time Hawaii was transitioning from being an independent kingdom to becoming part of the United States and its laws were changing accordingly. The key issue before the Supreme Court was whether Hawaiian law or American common law should apply in determining adverse possession rights since both differed significantly on this matter - under Hawaiian law at that time there would be no right to claim adverse possession while American common law allowed such claims after twenty years of continuous use. The court decided in favor of Kapiolani Estate Limited stating that even though Hawaii became a territory of America with all its laws applicable therein including those related to property rights; however these new rules could not retroactively validate any previous claims made under old local regulations which did not recognize adverse possessions as valid means for acquiring properties.

The dissenting opinion in the case of Kapiolani Estate, Limited v. Atcherley argued that the majority's decision was not consistent with previous rulings and interpretations of Hawaiian law. The dissenting justices believed that under Hawaiian law, a lease could be forfeited if rent was unpaid for 15 days after it became due, regardless of whether or not there had been a demand for payment. They also disagreed with the majority's interpretation of "re-entry," arguing that physical re-entry onto leased land wasn't necessary to enforce forfeiture; instead, they contended that legal proceedings to recover possession were sufficient. Furthermore, they asserted that even though Mrs. Atcherley paid her overdue rent before being evicted from her property by Kapiolani Estate Ltd., she did so only after legal proceedings had begun - which according to them should have resulted in forfeiture anyway as per existing laws at the time.