In the 1909 U.S. Supreme Court case Shevlin-Carpenter Company v. State of Minnesota, the court ruled in favor of Minnesota, upholding a state law that prohibited logging on certain lands to prevent deforestation and protect water resources. The Shevlin-Carpenter Company had argued that this law violated their rights under the Fourteenth Amendment's due process clause because it deprived them of property without compensation. However, the Supreme Court disagreed with this argument stating that states have a right to enact laws for public welfare including conservation efforts even if they limit private property rights. This decision was significant as it established precedent for environmental regulation by recognizing states' authority to regulate natural resources use within their borders for public benefit.

In the dissenting opinion for Shevlin-Carpenter Company v. State of Minnesota, Justice Harlan argued that the majority's decision was a departure from established legal principles regarding due process and property rights. He contended that the state had no right to confiscate private property without providing just compensation, as required by the Fourteenth Amendment. The law in question allowed Minnesota to seize logs cut illegally on public lands without compensating their current owners who may have purchased them unknowingly. Harlan believed this violated constitutional protections against taking private property for public use without fair payment, even if it served a legitimate public interest like preventing timber theft or preserving forests. He also disagreed with the majority's view that these logs were not truly 'property' because they were obtained unlawfully; he pointed out many cases where stolen goods still counted as 'property' under various laws and regulations.