In the 1892 case of People ex rel. Schurz v. Cook, the U.S Supreme Court dealt with a dispute over land ownership in Chicago's Lincoln Park. The park was originally owned by Jacob Rehm and his wife, who sold it to the city for public use as a park in 1869. However, after their deaths, their heirs claimed that they still held title to part of this property because the sale had not been properly executed according to Illinois law at that time which required both spouses' signatures on deeds transferring real estate. The City argued that even if there were any defects in conveyance initially, these were cured when Mrs. Rehm accepted payment for her interest and did not object during her lifetime to its use as a public park. The Supreme Court ruled against Rehm’s descendants stating that although there may have been some irregularities regarding how the original transaction was carried out between Mr.and Mrs.Rehm and City authorities back then; however since she never raised any objections while alive nor tried reclaiming said land before passing away - thus effectively acquiescing into its transformation into what is now known as Lincoln Park – such claims made posthumously by her offspring are invalid.

In the dissenting opinion for People ex rel. Schurz v. Cook, Justice Brewer argued that the majority's decision to uphold a law requiring all Chicago public schools to be non-sectarian was an overreach of government power and violated individual rights. He contended that while it is important for the state to ensure children receive education, how this education is delivered should not infrarily interfere with religious beliefs or practices. The justice believed that as long as basic educational standards are met, parents should have the freedom to choose a school which aligns with their religious convictions without being penalized by law. Furthermore, he expressed concern about potential misuse of such laws in future cases where they could be used against minority religions under guise of maintaining non-sectarianism in public schools.