In the Steele v. Culver case of 1908, the U.S Supreme Court ruled on a dispute involving land ownership and mineral rights in Colorado. The plaintiff, Steele, claimed that he had purchased mining claims from Culver who later sold them to another party despite having already sold them to Steele. The court was asked to determine whether or not these sales were valid under Colorado law which required all transfers of real property interest be made in writing. In its decision, the court upheld lower courts' rulings that verbal agreements for such transactions were invalid under state law and therefore could not be enforced by federal courts even if they would have been enforceable where they were made (in this case Illinois). This ruling reinforced states' rights over contract enforcement within their borders while also highlighting potential pitfalls for parties involved in interstate transactions.

In the dissenting opinion for Steele v. Culver, it was argued that the majority's decision to uphold a law prohibiting non-residents from hunting in Missouri violated the Privileges and Immunities Clause of Article IV of the Constitution. The dissenting justices believed that this clause protected citizens' right to travel freely between states and engage in lawful activities such as hunting. They contended that by upholding this law, which they viewed as discriminatory against out-of-state residents, the court was effectively allowing states to create barriers to interstate commerce and movement. This interpretation ran counter to their understanding of federalism principles enshrined in the Constitution designed specifically to prevent such parochial state laws from undermining national unity.