In the case of Port Gardner Investment Company v. United States, 1926, the Supreme Court ruled on a dispute regarding land ownership in Washington state. The Port Gardner Investment Company claimed that they had purchased certain lands from an individual who had received them as part of a federal grant under the Swamp Land Act of 1850. However, these lands were later declared to be public lands by the General Land Office and sold off to other parties. The company sued for compensation arguing that their title was valid because it derived from a federal grant while also claiming that government's action amounted to taking property without due process or just compensation. The Supreme Court disagreed with this argument stating that no patent or formal document transferring title was ever issued by the government for these lands; hence there was no basis for asserting any vested rights over them based on Swamp Land Act provisions alone. Furthermore, it held that even if such rights existed at some point, they would have been extinguished when Congress passed legislation in 1896 withdrawing all swamp and overflowed lands from sale or entry pending further examination and classification.

The dissenting opinion in the case of Port Gardner Investment Company v. United States argued that the majority's decision to uphold a tax on dividends received by shareholders was incorrect. The dissenters contended that this tax constituted double taxation, as it taxed both the corporation and its shareholders for essentially the same income. They also pointed out that such a tax could discourage investment and hinder economic growth, as it would reduce potential returns for investors. Furthermore, they disagreed with the majority's interpretation of relevant statutes and precedents, arguing instead that these sources supported their view against taxing dividends at both corporate and individual levels.