The U.S. Supreme Court case Mifflin v. Dutton in 1902 revolved around a dispute over land ownership and mineral rights in the state of Colorado. The plaintiff, Mifflin, claimed that he had acquired the property through a sheriff's sale following foreclosure on a mortgage held by him against the original owner, while defendant Dutton argued that he owned it due to his purchase from an assignee of tax certificates issued after non-payment of taxes by said original owner. The court ruled in favor of Dutton stating that under Colorado law at the time, tax deeds were considered conclusive evidence of valid title unless fraud or substantial error could be proven - neither was demonstrated here by Mifflin who merely questioned whether all legal requirements for issuance and delivery had been met without providing any concrete proof thereof.

In the dissenting opinion for Mifflin v. Dutton, Justice Harlan argued that the majority's decision to uphold a Pennsylvania law allowing creditors to seize and sell copyrighted material as property contradicted federal copyright laws. He contended that copyrights are not merely property rights but also personal rights granted by Congress under its constitutional authority. Therefore, they should be immune from state laws regarding debt collection. Furthermore, he asserted that this ruling could potentially undermine authors' ability to control their work and receive fair compensation for it because creditors could force them into unfavorable contracts or bankruptcy proceedings in order to obtain their copyrights. This would contradict the purpose of copyright protection: promoting creativity by ensuring creators can profit from their works.