In the 1900 case of Powers v. Slaght, the United States Supreme Court addressed a dispute over land ownership in Michigan. The plaintiff, Powers, claimed that he had purchased land from Slaght and paid for it fully but never received a deed to confirm his ownership. Instead, Slaght sold the same piece of property to another party who then filed an eviction notice against Powers. The lower court ruled in favor of this third party based on their possession of the deed despite Power's claim that he was defrauded by Slaght. Powers appealed to the Supreme Court arguing that his payment for and improvement upon the property should be considered as evidence towards his rightful ownership under Michigan law which recognized "equitable title" or rights derived from actions taken indicating intent to own (like improving or maintaining property). The Supreme Court agreed with Powers' interpretation and reversed the decision of lower courts stating that even without formal legal title (a deed), equitable considerations could establish rightful ownership if proven satisfactorily.

In the dissenting opinion for Powers v. Slaght, Justice Harlan argued that the majority's decision was a misinterpretation of Michigan law and an overreach of federal authority. He contended that it was not within the purview of the Supreme Court to interpret state laws unless there is a clear violation or conflict with federal law or constitution. In this case, he believed no such conflict existed as Michigan courts had already determined their own interpretation which should be respected by Federal Courts under principles of comity and federalism. Furthermore, he disagreed with majority’s view on how certain terms were defined in relation to property rights involved in this case; arguing they ignored established legal definitions used by Michigan courts themselves. Overall, his dissent emphasized respect for states' rights and autonomy in interpreting their own laws without interference from Federal judiciary unless absolutely necessary due to constitutional conflicts.