In the 1904 case of Keely v. Moore, the United States Supreme Court ruled on a dispute involving land ownership in Oklahoma. The plaintiff, Keely, claimed that he had purchased a plot of land from an individual who was part Choctaw and Chickasaw by blood. However, under existing laws at that time (the Atoka Agreement), members of these tribes were not allowed to sell their allotted lands within twenty-one years without approval from the U.S government. The defendant, Moore, argued that since this law was violated when Keely bought his property directly from the tribal member without governmental consent; therefore it should be considered void and he should have rightful claim over it instead as he later received patent for same piece of land issued by US Government. The court sided with Moore stating that although there might be some exceptions where such sales could take place legally but those did not apply here because no evidence was presented showing any legal exception applied in this case or any fraud occurred during issuance of patent to Moore which would invalidate it. This decision reinforced federal protections for Native American lands against unauthorized sale or transfer while also highlighting importance of proper legal procedures in real estate transactions.

In the dissenting opinion for Keely v. Moore, it was argued that the majority's decision to uphold a law allowing creditors to seize and sell debtor property without prior notice or hearing violated due process rights under the Fourteenth Amendment. The dissenting justices believed that this ruling effectively permitted states to deprive individuals of their property without any form of judicial proceeding, which they viewed as unconstitutional. They contended that such laws were inherently unjust and could lead to abuses by unscrupulous creditors who might seize more than what is owed them or unfairly target vulnerable debtors. Therefore, in their view, these laws should be struck down as violations of constitutional protections against arbitrary deprivation of property.