The U.S. Supreme Court case Michels v. Olmstead in 1894 revolved around a dispute over land ownership and the interpretation of statutes related to it. The plaintiff, Michels, claimed that he had purchased certain lands from the state of Wisconsin under an act granting lands for railroad purposes but was being denied possession by Olmstead who held prior title deeds to the same property. The court ruled in favor of Olmstead stating that while there may have been irregularities or errors made by public officers during the sale process, these did not invalidate his original titles nor could they be used as grounds for transferring ownership rights to another party without due legal process such as foreclosure proceedings on defaulted mortgages or tax liens which were not applicable here.

In the dissenting opinion for Michels v. Olmstead, it was argued that the majority's decision to uphold a law prohibiting non-residents from fishing in Washington state waters violated the Privileges and Immunities Clause of Article IV of the U.S. Constitution. The dissenting justices believed this clause should protect citizens' right to fish in all states, not just their home state. They also disagreed with the majority's interpretation of "common property," arguing that natural resources like fish should be considered common property accessible by all U.S. citizens rather than being subject to individual state control or ownership rights. Furthermore, they contended that restricting access based on residency could lead to unfair monopolization and exploitation of these resources by residents at non-residents' expense.