In the case of Rowe v. Phelps in 1893, the United States Supreme Court ruled on a dispute involving land ownership and inheritance rights. The plaintiff, Rowe, claimed that he was entitled to certain lands based on an alleged will from his deceased relative. However, the defendant, Phelps (who had purchased said lands), argued that no such will existed and therefore Rowe's claim was invalid. The court sided with Phelps after finding insufficient evidence supporting the existence of a valid will favoring Rowe as heir to these properties. This decision upheld previous rulings by lower courts which also found in favor of Phelps due to lack of substantial proof regarding any legitimate testamentary document left by the decedent for Rowe.

In the dissenting opinion for Rowe v. Phelps, it was argued that the majority's decision to uphold a state law prohibiting non-residents from fishing in its waters violated the Privileges and Immunities Clause of Article IV of the Constitution. The dissenting justices believed that this clause guaranteed citizens of each state equal access to all privileges and immunities offered by every other state, including natural resources like fish. They contended that while states have authority over their own natural resources, they cannot discriminate against out-of-state residents regarding their use. Therefore, they viewed such laws as unconstitutional barriers to interstate commerce and an infringement on individual rights granted under the Constitution.