In the 1892 case of Lehnen v. Dickson, the United States Supreme Court addressed a dispute over land ownership in Arkansas. The plaintiff, Lehnen, claimed that he had purchased certain lands from the state of Arkansas which were part of an indemnity grant to railroads by Congress but were sold before being certified as such by federal authorities. He argued that his purchase was valid and sought to eject Dickson who held possession under a subsequent patent issued by the United States after certification. However, it was ruled against him on grounds that until these lands had been identified and certified for railroad purposes they remained public lands subject to disposal under general laws; hence their sale did not pass title away from government's control or prevent issuance of patents thereafter based upon preemption rights or homestead entries made while they were still public domain. Therefore, Dickson’s claim through U.S patent superseded any prior state-granted titles including those obtained by Lehnen.

The dissenting opinion in the Lehnen v. Dickson case argued that the majority's decision was based on an incorrect interpretation of law and precedent. The dissenting justices believed that a contract for labor should not be considered void simply because it involved work on Sunday, which was prohibited by state law at the time. They contended that such contracts were only illegal if they explicitly required work to be performed on Sundays, but not if they merely allowed for this possibility. Furthermore, they disagreed with the majority's view that a person who entered into such a contract could then refuse to pay for any services rendered under it without facing legal consequences. This, according to them, would unjustly enrich one party at the expense of another and undermine faith in contractual agreements more generally.