In the case of Kneeland v. Luce, 1891, the Supreme Court dealt with a dispute over land ownership in Michigan. The plaintiff, Kneeland, claimed that he had purchased a piece of property from the federal government before it was officially surveyed and therefore owned it outright. However, after the survey was completed years later by defendant Luce (the Governor), part of this land fell into an area designated as school lands under state law which were not open for private purchase at that time when Kneeland bought them. The court ruled against Kneeland stating that his purchase could not be validated because it occurred prior to official surveying and designation by state authorities; thus violating established procedures for public land sales set forth in both federal and state laws.

In the dissenting opinion for Kneeland v. Luce, it was argued that the majority's decision to uphold a Michigan law requiring all voters to be literate in English violated the Fourteenth Amendment of the U.S. Constitution. The dissenting justices contended that literacy tests were discriminatory and served as a means of suppressing immigrant votes, particularly those from non-English speaking countries. They believed this requirement unfairly targeted certain ethnic groups and created an unequal voting system, thus infringing on their rights to equal protection under the law as guaranteed by the Fourteenth Amendment. Furthermore, they expressed concerns about potential abuses of such laws by those in power who could manipulate them for political gain or use them as tools for discrimination against minority groups.