In the case of Maddox v. Burnham, 1894, the U.S Supreme Court dealt with a dispute over land ownership in Georgia. The plaintiff, Maddox, claimed that he had purchased a tract of land from one Mr. Hillyer who was acting as an agent for Mrs. Burnham and her children - the defendants in this case. However, Mrs.Burnham argued that she never authorized Hillyer to sell any part of her property and thus refused to recognize Maddox's claim on it. The court ruled in favor of Mrs.Burnham stating that there was no evidence proving that she had given express authority to Hillyer to act on her behalf or sell any portion of her property without explicit consent from herself or through legal documentation such as power-of-attorney papers etc., which were absent in this situation. Furthermore, even if implied agency could be established (which wasn't), it would still not grant him powers beyond those explicitly stated by his principal (Mrs.Burnham). Therefore since there was no proof showing either express or implied authorization granted by Mrs.Burnham towards selling off parts of her estate; henceforth all claims made by Maddox regarding his purchase were deemed invalid.

In the dissenting opinion for Maddox v. Burnham, it was argued that the court majority had erred in its interpretation of Georgia's tax laws and their application to this case. The dissent contended that under Georgia law, a lien on property for unpaid taxes did not automatically result in forfeiture of ownership rights if those taxes were not paid within a certain timeframe. Instead, they believed that additional legal action would be required by the state to enforce such a forfeiture. Therefore, they disagreed with the majority's ruling which upheld an auction sale of land based on non-payment of taxes as valid transfer of title without requiring further enforcement actions from the state government.