In the 1890 case of Pennoyer v. McConnaughy, the U.S. Supreme Court dealt with a dispute over land titles in Oregon. The plaintiff, Pennoyer, claimed that he had purchased land from an individual who obtained it through a federal grant under the Swamp Land Act of 1850. However, this was disputed by McConnaughy and others who argued they held valid claims to these lands based on purchases made at tax sales conducted by state authorities due to unpaid taxes on said properties. The court ruled in favor of McConnaughy stating that while there were irregularities in how Oregon handled its swamp lands initially - including failing to provide proper notice for delinquent taxpayers before selling their property - those issues did not invalidate subsequent good faith purchasers' rights like those of McConnaughy's group. Furthermore, it stated that even though Congress could have directly granted such lands to states instead of individuals (which would have avoided such disputes), since it chose not to do so here and allowed states discretion over them instead; any complaints about how they managed these should be addressed within each respective state rather than federally.

In the dissenting opinion for Pennoyer v. McConnaughy, Justice Field disagreed with the majority's decision to uphold a state law that allowed landowners to sell their property without notifying all interested parties. He argued that this violated due process rights under the Fourteenth Amendment of the Constitution because it deprived individuals of their property without giving them an opportunity to defend themselves in court. Furthermore, he contended that such laws could lead to fraud and corruption as they enabled unscrupulous individuals or entities to acquire properties through deceitful means by taking advantage of unsuspecting owners who were not aware of pending sales transactions involving their lands. The justice believed that every person should be given fair notice and an opportunity for hearing before being deprived of any significant property interest.