In the 1904 case of Small v. Rakestraw, the United States Supreme Court dealt with a dispute over land ownership in Indiana. The plaintiff, Small, claimed that he had purchased a piece of property from an individual who had acquired it through adverse possession (a process by which one can gain legal ownership of property by occupying it for a certain period). However, the defendant, Rakestraw argued that they were the rightful owner as their family had originally owned and occupied this land before leaving due to threats from Native Americans. They asserted that these circumstances should be considered involuntary abandonment and thus not subject to adverse possession laws. The court ruled in favor of Small stating that regardless of why previous owners left or did not use their property; if they fail to assert their rights within statutory limits set for adverse possession claims then those rights are lost. This ruling reinforced principles regarding real estate law and clarified how courts interpret cases involving disputes about abandoned properties.

In the dissenting opinion for Small v. Rakestraw, Justice Harlan disagreed with the majority's interpretation of the Sherman Antitrust Act and its application to labor unions. He argued that this law was intended to prevent monopolies and protect competition in business, not regulate trade union activities or limit workers' rights to strike. According to him, a collective refusal by employees to work under certain conditions should not be considered as an illegal restraint of trade or commerce among states. The justice also criticized his colleagues for ignoring previous court decisions which had upheld these principles and warned that their ruling could have serious implications on labor relations in America.