The U.S. Supreme Court case United States v. Detroit Timber and Lumber Company in 1905 revolved around a dispute over the sale of public lands by the federal government to private entities for timber harvesting purposes. The Detroit Timber and Lumber Company had purchased land from the government under an act that allowed such sales only if they were "unfit for cultivation." However, it was later discovered that these lands were indeed fit for cultivation, leading to allegations of fraud against the company. The court ruled in favor of the lumber company, stating that once a patent (a deed from a government) has been issued on land sold by the federal government, its validity cannot be challenged even if there is evidence suggesting fraudulent procurement or mistake by officials involved in assessing its cultivability status at time of sale.

In the dissenting opinion for United States v. Detroit Timber and Lumber Company, Justice Harlan argued that the majority's interpretation of the law was incorrect. He believed that Congress had intended to grant land to railroad companies only if they could prove they had completed their rail lines within a specified time period. If not, then those lands should revert back to public domain status rather than being sold off by the government at below-market prices as was done in this case with Detroit Timber and Lumber Co. Furthermore, he disagreed with how casually his colleagues dismissed evidence suggesting fraud on part of these corporations when acquiring such lands from federal government; arguing instead for stricter scrutiny over corporate actions especially when it involves public resources or property rights which belong collectively to all citizens rather than just a select few business interests.