In the 1914 case of Southern Operating Company v. Hays, County Clerk of Hamilton County, Tennessee, the Supreme Court dealt with a dispute over property rights and taxation. The Southern Operating Company had purchased land in Tennessee that was previously owned by another company which had failed to pay its taxes. As such, the county clerk seized and sold it for tax purposes before Southern Operating could take possession. The court ruled in favor of Hays (the county clerk), stating that he acted within his legal authority to seize and sell properties for unpaid taxes even if they were recently bought by new owners who weren't responsible for those debts themselves. This decision reinforced local governments' power to enforce tax laws strictly.

The dissenting opinion in the case of Southern Operating Company v. Hays, County Clerk of Hamilton County, Tennessee argued that the majority's decision was flawed because it failed to consider important aspects of state law and jurisdiction. The dissent pointed out that under Tennessee law, a corporation could not be sued outside its home county unless specifically allowed by statute. In this case, there was no such statutory provision allowing for suit against Southern Operating Company in Hamilton County where it did not reside or have an office. Therefore, according to the dissenters' interpretation of state law and principles of jurisdictional fairness, the lawsuit should have been dismissed on procedural grounds rather than decided on its merits as done by the majority.