In the case of South Branch Lumber Company v. Ott, the U.S. Supreme Court ruled in 1891 on a dispute over land ownership and timber rights. The South Branch Lumber Company had purchased land from an individual who claimed to have acquired it through a patent issued by the United States government under swamp-land laws. However, another party named Ott also claimed ownership of this same piece of property due to his purchase from a state sale for unpaid taxes on said property. The court held that because there was no evidence showing that the original grantee or his successors had ever paid any taxes on this land before its sale for delinquent taxes, nor did they take possession or make improvements upon it within five years after such patent was issued as required by law; therefore, their claim to title became void and passed back into public domain making subsequent tax-sale valid and giving rightful title to Ott.

The dissenting opinion in the case of South Branch Lumber Company v. Ott argued that the majority's decision was incorrect because it failed to properly interpret and apply Michigan law regarding property rights. The dissent contended that under Michigan law, a person who improves another's property without their consent but with good faith belief they own the land should be compensated for those improvements if it turns out they do not actually own the land. In this case, South Branch Lumber Company had made significant improvements on what they believed to be their property before discovering that Ott was indeed the rightful owner. Therefore, according to this interpretation of Michigan law, South Branch should have been entitled to compensation for these improvements from Ott when he took possession of his rightfully owned land. The dissent criticized the majority for failing to recognize and uphold this principle in its ruling.