In the 1908 case of Ubarri v. Laborde, the United States Supreme Court ruled on a dispute involving property rights in Puerto Rico. The plaintiff, Ubarri, claimed that he had purchased land from Laborde and sought to have his title recognized by the court. However, Laborde argued that he had never sold any land to Ubarri and therefore still owned it himself. The lower courts sided with Laborde but upon appeal to the Supreme Court, Justice Holmes delivered an opinion reversing this decision. The key issue was whether or not a deed existed proving that ownership of the land had been transferred from Laborde to Ubarri. Although no such document could be found in Puerto Rico's public records (as required by local law), there was evidence suggesting one may have once existed but got lost over time due to negligence or mishap rather than fraudulent intent. Justice Holmes concluded that even though strict adherence to formalities is important for maintaining order in property transactions; fairness should also play a role when deciding cases like these where evidence suggests a valid transaction took place despite lack of official documentation.

In the dissenting opinion for UBARRI v. LABORDE, 1908, it was argued that the majority's decision to uphold a Puerto Rican court's ruling failed to properly consider the unique legal status of Puerto Rico as an unincorporated territory of the United States. The dissenting justices believed that U.S. constitutional protections should extend fully to residents of Puerto Rico and other territories, regardless of their incorporation status or lack thereof. They contended that by upholding a local law which allowed creditors to seize debtor’s property without prior notice or hearing violated due process rights guaranteed under U.S Constitution’s Fourteenth Amendment. The dissenters expressed concern about potential abuses stemming from such laws and emphasized on extending full constitutional protection in all American jurisdictions including territories like Puerto Rico.