In the 1918 case of Mount Saint Mary's Cemetery Association v. Mullins, the United States Supreme Court dealt with a dispute over land ownership and usage rights between a cemetery association and an individual named Mullins. The cemetery association had purchased land from Mullins' father-in-law, who retained certain usage rights to the property for himself and his family members. After his death, these rights were passed onto Mullins through inheritance. However, when he attempted to exercise these rights by burying deceased family members on the property in question, he was prevented from doing so by the cemetery association which claimed full ownership of all lands within its boundaries without any encumbrances or restrictions. The court ruled in favor of Mr.Mullin stating that although it is generally true that cemeteries have broad powers over their properties under state law; they cannot infringe upon private contractual agreements made prior to their acquisition of said properties unless those agreements are explicitly nullified or modified during purchase negotiations or subsequent legal proceedings.

In the dissenting opinion for Mount Saint Mary's Cemetery Association v. Mullins, Justice Holmes argued that the cemetery association should not be exempt from paying taxes on its property just because it was a religious organization. He believed that all properties used for profit-making purposes should be taxed equally, regardless of who owns them or what they are used for. In his view, allowing such exemptions would create an unfair burden on other taxpayers and could potentially lead to abuses by organizations claiming religious status to avoid taxation. Furthermore, he contended that there was no constitutional basis for granting tax exemptions based solely on religious affiliation or purpose; rather, any such exemptions should be granted by legislative action only after careful consideration of their potential impacts and benefits.