In the United States v. Morgan case of 1911, the Supreme Court ruled on a dispute involving land ownership and property rights. The U.S government had sold a parcel of land in Louisiana to Thomas Freeman in 1806, who then sold it to John McDonogh. After McDonogh's death, his will stipulated that all his properties be used for educational purposes which led to several schools being built on these lands including Tulane University and Johns Hopkins University. However, when oil was discovered on this piece of land years later, descendants of Thomas Freeman claimed they were rightful owners since their ancestor never received payment from the government sale due to an administrative error. The Supreme Court held that even though there was indeed an oversight with regards to payment during the original transaction between Freeman and the U.S Government back in 1806; such claims by heirs or descendants are invalid after so many years have passed (over a century). This is because allowing such claims would create uncertainty over property titles leading potentially chaotic legal disputes over real estate transactions across America. Therefore, despite any initial errors made during its sale by US Government more than hundred years ago; title possession remained valid with current owner(s) as per law.

In the dissenting opinion for United States v. Morgan, Justice Holmes argued that the government had no right to interfere with a private contract between two parties unless it was in violation of antitrust laws or other regulations. He believed that the majority's decision to void an agreement between a railroad company and its customers over freight rates was an overreach of judicial power. According to him, if there were any issues with this agreement, they should have been addressed by Congress through legislation rather than by courts imposing their own views on what constitutes fair business practices. This case represented one instance where he disagreed with his colleagues' tendency towards judicial activism and favored a more restrained approach instead.