In the 1902 case of Manley v. Park, the U.S Supreme Court dealt with a dispute over land ownership in California. The plaintiff, Manley, claimed that he had purchased a piece of property from an individual who had acquired it through preemption rights under federal law. However, before this purchase was made official by patenting (the process of legally recognizing someone's claim to public lands), another person named Park also laid claim to the same property and received their own patent for it. The court ruled in favor of Park on grounds that his patent was issued first and therefore took precedence over any subsequent claims or sales related to the land in question. This decision affirmed that when multiple parties lay claim to public lands under preemption laws, whoever receives their patent first is considered the rightful owner regardless of any prior agreements or transactions involving said lands.

The dissenting opinion in the Manley v. Park case argued that the majority's decision to uphold a law prohibiting non-residents from hunting or fishing within a state, unless they were accompanied by a resident guide, was unconstitutional. The dissenters believed this law violated both the Privileges and Immunities Clause of Article IV and the Equal Protection Clause of the Fourteenth Amendment. They contended that these constitutional provisions guarantee all citizens equal access to public resources such as wildlife, regardless of their state residency status. Therefore, any legislation restricting this right based on residency is discriminatory and unconstitutional. Furthermore, they disagreed with the majority's interpretation that states have exclusive ownership over wildlife within their borders; instead arguing for shared stewardship among all states due to migratory nature of many species.