In the case of Swigart v. Baker (1912), the United States Supreme Court addressed a dispute over land ownership in California. The plaintiff, Swigart, claimed that he had purchased land from an individual who had obtained it through preemption rights under federal law. However, the defendant, Baker, argued that this was not valid as the original owner did not meet all necessary requirements for preemption and thus could not legally sell it to Swigart. The court ruled in favor of Baker stating that even though there were some irregularities with how the government initially granted title to this property; those issues were resolved when they issued a patent for it later on which made any previous defects irrelevant. Therefore since no fraud or mistake was involved in issuing such patent by Land Department officials and because these officials have exclusive jurisdiction over public lands until legal title passes out of United States into hands of private individuals; their decision is final unless successfully appealed within department itself before issuance of said patent.

In the dissenting opinion for SWIGART v. BAKER, Justice Holmes argued that the majority's decision was based on a misinterpretation of the law and an overreach of judicial power. He contended that it was not within the court's jurisdiction to decide whether or not a state had violated its own laws unless there were clear constitutional implications at stake. In this case, he believed that no such implications existed and therefore, it should have been left to Kansas courts to interpret their own statutes regarding insurance companies' liability in cases involving policyholders who committed suicide. Furthermore, he disagreed with the majority's interpretation of "accidental means" as excluding suicides; arguing instead that if someone unintentionally causes their own death (as might be argued in some suicide cases), then they have died by accidental means under any reasonable definition of those words.