In the case of Roberts v. Lewis in 1893, the U.S Supreme Court was tasked with determining whether a will that had been executed and admitted to probate in California could be contested by an heir who lived in Nevada. The decedent, a resident of California at his time of death, left behind property both within and outside the state. His son from Nevada claimed he was not properly notified about the proceedings concerning his father's estate and sought to contest it under Nevada law which allowed for such action even after probate has been granted elsewhere. The court ruled against him stating that once a will is proven validly executed according to laws where it was made (in this case - California), its validity cannot be questioned anywhere else unless there are issues regarding real property located outside jurisdiction where will was proved or if fraud or mistake can be shown affecting proceedings leading up to admission into probate. Therefore, since no such allegations were made here, they held that son’s rights as an heir were subject only to those recognized under Californian law.

The dissenting opinion in the Roberts v. Lewis case argued that the majority's decision to uphold a state law prohibiting polygamy was incorrect. The dissenters believed that this ruling violated an individual’s right to freedom of religion, as protected by the First Amendment. They contended that religious beliefs and practices should be free from government interference unless they posed a clear threat to public safety or morality. In their view, while polygamy may not align with mainstream societal norms, it did not constitute such a threat and thus should have been allowed under constitutional protections for religious liberty.