In the 1906 case of Urquhart, Sheriff v. Brown, the United States Supreme Court dealt with a dispute over property rights and jurisdiction. The plaintiff was a sheriff from Washington state who had seized certain goods belonging to Brown as part of an execution process on behalf of creditors. However, at that time, these goods were in transit on a railway line passing through Idaho and Montana before reaching their destination in Washington State. Therefore, the question arose whether or not this seizure was legal since it occurred outside the territorial limits where he held office. The court ruled against Sheriff Urquhart stating that his authority did not extend beyond his own county's borders unless explicitly provided by statute law which wasn't applicable here. Thus, any act performed outside those boundaries is considered null and void due to lack of jurisdictional power even if such action may be beneficial for parties involved within his territory.

In the dissenting opinion for Urquhart v. Brown, Justice Harlan argued that the majority's decision to uphold a Louisiana law allowing non-unanimous jury verdicts in certain cases was inconsistent with the Constitution's guarantee of equal protection under the law. He contended that this provision was designed specifically to discriminate against African Americans by diluting their potential influence on juries and thereby undermining their civil rights. Furthermore, he maintained that such laws were part of a broader pattern of racial discrimination in Southern states following Reconstruction, which included measures aimed at disenfranchising black voters and segregating public facilities. In his view, these practices violated both the letter and spirit of constitutional amendments enacted after Civil War intended to secure equality before law for all citizens regardless race or color.