In the Lytle v. Lansing case of 1892, the US Supreme Court ruled on a dispute over land ownership in Kansas. The plaintiff, Lytle, claimed that he had purchased the land from an individual who had obtained it through preemption rights under federal law. However, Lansing argued that he was the rightful owner because he bought it at a tax sale after local authorities seized and sold it due to unpaid taxes by its previous owners (the railroad company). The court sided with Lytle stating that state laws allowing for such tax sales were not applicable when they conflicted with federal statutes governing public lands distribution. Therefore, since the original sale of land to Lansing was invalid as per Federal Law which superseded State Law in this matter; hence title could not have passed onto him via tax deed purchase making Lytle's claim valid and recognizing him as lawful owner.

In the dissenting opinion for Lytle v. Lansing, Justice Brewer argued that the majority's decision was inconsistent with previous rulings of the court and violated principles of equity. He contended that a mortgage is not an absolute conveyance but merely a security for debt, and thus it should be treated as such in law. The debtor retains equitable title to the property until foreclosure or some other event extinguishes his rights. Therefore, he believed that Mr. Lytle retained an interest in his land even after defaulting on his loan payments because there had been no foreclosure sale at which legal title could have passed to another party. Furthermore, he disagreed with the majority's interpretation of Michigan law regarding redemption rights following a sheriff’s sale under execution; according to him, this right existed irrespective of whether any surplus remained from such sale.