In the case of McCandless v. Pratt, Land Commissioner of Hawaii in 1908, the Supreme Court dealt with a dispute over land rights in Hawaii. The plaintiff, McCandless, claimed that he had been unlawfully denied his right to purchase certain public lands by the defendant, Pratt who was then serving as Land Commissioner of Hawaii. He argued that under an act passed by Congress known as "The Hawaiian Organic Act", all citizens were given equal opportunity to buy and possess such lands. However, Pratt contended that this law did not apply because it conflicted with existing Hawaiian laws which gave preference to native Hawaiians for land purchases. The Supreme Court ruled in favor of McCandless stating that when Hawaii became a territory of the United States through annexation; its local laws could be superseded by federal legislation if there was any conflict between them. Therefore, according to "The Hawaiian Organic Act" enacted by Congress after annexation which guaranteed equal rights for all U.S citizens including those living in territories like Hawaii; no preferential treatment should be given based on race or ethnicity while selling public lands.

In the dissenting opinion for McCandless v. Pratt, Justice Harlan disagreed with the majority's interpretation of Hawaii's Organic Act. He argued that Congress intended to grant all public lands in Hawaii to the Territory upon its establishment and did not intend for any lands to be held by private individuals or corporations without a specific grant from Congress or the Hawaiian government. Therefore, he believed that McCandless had no right to claim ownership over land simply because it was included within his leasehold boundaries if there was no explicit deed granting him such rights. Furthermore, he contended that even if McCandless could prove an implicit transfer of title through possession and use of the land, this would still not constitute a valid claim under federal law since it contradicts Congressional intent as expressed in the Organic Act.