In the case of New Orleans v. Gaines's Administrator (1890), the U.S. Supreme Court ruled in favor of Myra Clark Gaines, who had been engaged in a long legal battle over her inheritance rights to valuable property located in New Orleans. The city claimed ownership based on a sale that occurred after the death of Daniel Clark, Myra’s father, while she argued that this sale was illegal as it happened without her knowledge or consent and she was his only legitimate heir. The court held that Mrs. Gaines had proven beyond reasonable doubt both her legitimacy and her father's wealth at his death; therefore, she was entitled to inherit his estate including any properties he owned at the time of his demise which were sold illegally by executors afterwards.

In the dissenting opinion for New Orleans v. Gaines's Administrator, Justice Lamar argued that the majority had erred in their interpretation of Louisiana law and its application to this case. He contended that under Louisiana law, a judgment could not be rendered against an absent defendant unless they were properly represented in court by someone with legal authority to act on their behalf. In this case, he believed that Myra Clark Gaines was not adequately represented during her father’s estate proceedings because her interests were adverse to those of the other parties involved. Therefore, any judgments made without proper representation should be considered null and void. Furthermore, he disagreed with the majority's assertion that Mrs.Gaines' claim was barred due to laches (unreasonable delay). He pointed out there is no statute of limitations for actions involving real property rights in Louisiana; thus she should have been allowed to pursue her claim regardless of how much time had passed since her father’s death.