In the case of Lawton v. Steele, 1893, the U.S. Supreme Court was tasked with determining whether a New York state law that prohibited the use of certain types of fishing nets violated property rights protected by the Fourteenth Amendment. The court ruled in favor of Steele and upheld the law, stating that it did not infrive upon any constitutional rights but rather served to protect wildlife from overfishing and depletion - an issue considered as a legitimate exercise of police power for public good. This ruling established an important precedent regarding states' ability to regulate natural resources within their borders without violating private property rights under federal constitution.

In the dissenting opinion for Lawton v. Steele, Justice Brewer argued that the New York law in question was unconstitutional because it violated property rights without due process of law. He contended that while states have a right to regulate fishing and hunting within their borders, they cannot arbitrarily destroy or confiscate private property under the guise of regulation. In this case, he believed that destroying privately owned nets used for fishing was an overreach of state power and infringed upon individual rights protected by the Fourteenth Amendment. Furthermore, he disagreed with majority's interpretation of "public interest," asserting instead that public interest should not be used as a justification to violate constitutionally protected rights.