In the case of Stewart v. Ramsay in 1916, the U.S. Supreme Court dealt with a dispute over land ownership and mineral rights in Colorado. The plaintiff, Stewart, claimed that he had purchased mining claims from Ramsay but later discovered that these claims were invalid because they were located on public lands not open for private acquisition under federal law at the time of purchase. He sued to recover his money arguing fraudulent misrepresentation by Ramsay who knew or should have known about this legal impediment when selling him those mining rights. The court ruled against Stewart stating that both parties were equally ignorant about the status of these lands at the time of transaction and there was no evidence showing intentional fraud by Ramsay. Furthermore, it held that even if such knowledge existed on part of seller (Ramsay), buyer's (Stewart) ignorance wouldn't entitle him to relief as he failed to exercise due diligence before purchasing those properties which is expected from anyone entering into such transactions involving valuable property interests.

In the dissenting opinion for Stewart v. Ramsay, it was argued that the majority's decision to uphold a tax on inheritances from non-residents contradicted previous rulings of the Court. The dissent contended that this case should have been treated similarly to other cases where taxes were imposed by states on property located outside their jurisdiction, which had previously been deemed unconstitutional. It was further asserted that an inheritance is not a privilege granted by a state but rather a right and thus should not be subject to taxation under these circumstances. Moreover, it was suggested that such taxation could lead to double-taxation if multiple states claimed jurisdiction over the same inheritance - something seen as fundamentally unfair and contrary to principles of justice.