In the case of United States v. Bowling et al., 1920, the Supreme Court dealt with a dispute over land ownership in Kentucky. The U.S government claimed that it had acquired title to certain lands through treaties made with Cherokee Indians in 1791 and 1819. However, defendants argued they held valid titles to these lands based on grants from Virginia prior to those treaties. The court ruled against the U.S government stating that at no point did Native American tribes possess an absolute right of alienation to their tribal lands without consent from Congress; thus, any treaty could not convey clear title if there were pre-existing claims or rights granted by other states (in this case Virginia). Therefore, even though federal law generally superseded state law under the Supremacy Clause of Constitution, here because Virginia's grant preceded federal involvement and was never explicitly invalidated by Congress or subsequent treaty terms - its validity remained intact.

The dissenting opinion in the United States v. Bowling et al., 1920 case argued that the majority's decision to uphold a conviction based on circumstantial evidence was flawed. The dissenting justices believed that there were significant gaps and inconsistencies in the prosecution's narrative, which raised reasonable doubt about the defendants' guilt. They contended that it was not enough for circumstances to create suspicion or even strong probability of guilt; they must produce moral certainty beyond reasonable doubt. In this case, they felt such certainty had not been achieved due to lack of direct evidence linking defendants with crime committed and thus, upheld their belief in favor of acquittal.