In the case of Orchard v. Alexander in 1894, the U.S. Supreme Court dealt with a dispute over land ownership and inheritance laws. The plaintiff, Orchard, claimed that he was entitled to certain lands under an English will while the defendant, Alexander, held title to these lands through purchase from other parties who also claimed rights under different provisions of the same will. The court ruled against Orchard stating that his claim was not valid as it did not comply with certain requirements set out by Kentucky law for foreign wills to be recognized and enforced within its jurisdiction; specifically regarding registration within a specified time period after probate abroad or after arrival in Kentucky if later than probate abroad. Therefore, even though Orchard may have had legitimate claims under English law where the original will was made and executed; those claims were deemed irrelevant because they weren't properly registered according to local state laws where enforcement was sought.

In the dissenting opinion for Orchard v. Alexander, it was argued that the majority had misinterpreted and misapplied the law regarding land ownership rights. The dissenting justices believed that Mr. Orchard's claim to a piece of property should have been upheld because he had made significant improvements on it with his own labor and resources, demonstrating an intent to possess and control it as his own. They also pointed out that there were no clear indications in the record showing any intention by Mr. Alexander to assert or maintain control over this particular parcel of land during all those years when Mr. Orchard was making these improvements upon it; thus they felt that under common law principles of adverse possession, which recognize long-term possession coupled with substantial improvement as evidence of rightful ownership, Mr. Orchard should be considered its legal owner rather than Mr.Alexander.