In the 1891 case Martin v. Gray, the U.S. Supreme Court addressed a dispute over land ownership in Arkansas between two parties: one who had purchased the property at a tax sale and another claiming to be its rightful owner due to inheritance. The court ruled that while state law allowed for properties sold at tax sales to be redeemed within two years by paying back taxes with interest, this did not apply if there was no proper notice given of such sales as required by due process under the Fourteenth Amendment. In this particular case, it was found that no sufficient notice had been given about the tax sale where Martin bought his claim on the property from Gray's estate; therefore, he could not legally own it even though he'd paid all relevant taxes and fees associated with its purchase and upkeep since then.

In the dissenting opinion for Martin v. Gray, it was argued that the majority's decision to uphold a state law prohibiting non-residents from hunting or fishing on their own private property in Louisiana violated both the Privileges and Immunities Clause of Article IV and the Fourteenth Amendment. The dissenting justices believed that this law unfairly discriminated against out-of-state residents by denying them rights enjoyed by Louisiana citizens. They contended that while states have broad power to regulate hunting and fishing within their borders, they cannot use this power to infringe upon constitutional protections afforded to all U.S citizens regardless of residency status. Furthermore, they disagreed with the majority's assertion that such laws were necessary for conservation purposes as there were other less discriminatory means available for achieving these ends.