In the 1908 case of Reid v. United States, the U.S Supreme Court dealt with a dispute over land ownership in Puerto Rico. The plaintiff, Reid, claimed that he had purchased a piece of property from its original owner and was therefore entitled to it. However, after the Spanish-American War ended in 1898 and Puerto Rico became a territory of the United States, this same property was sold by an American military officer to another party who then transferred it to the defendant (United States). The court ruled against Reid stating that his claim lacked validity because at no point did he have legal title or possession of said property under either Spanish or American law during relevant periods. Furthermore, they found that any sale made by an unauthorized person does not transfer valid title even if purchaser is unaware seller lacks authority; thus making subsequent sales void as well.

In the dissenting opinion for Reid v. United States, it was argued that the defendant's constitutional rights were violated due to a lack of proper legal representation during his trial. The dissenting justices believed that Reid had not been given an adequate opportunity to consult with counsel and prepare his defense before being tried for murder in Alaska, which at the time was still a territory without full constitutional protections. They also disagreed with the majority's interpretation of territorial jurisdiction and contended that Congress did not have unlimited power over territories like Alaska but should respect basic individual rights regardless of location or status as state or territory. Furthermore, they expressed concern about potential abuses if such broad congressional powers were recognized by courts.