In the case of West v. Cabell in 1893, the US Supreme Court dealt with a dispute over land ownership and mineral rights. The plaintiff, West, claimed that he had purchased property from Cabell's father before his death and was therefore entitled to its possession as well as any minerals found on it. However, Cabell argued that her father did not have clear title to sell because there were other heirs involved who hadn't agreed to the sale. The court ruled in favor of West stating that even though some heirs may not have been aware or consented to the sale at first; they later ratified it by accepting benefits from it without protest for many years which gave them no right now to question its validity.

In the dissenting opinion for West v. Cabell, Justice Brewer argued that the court had overstepped its bounds by ruling on a matter of state law. He contended that it was not within the purview of federal courts to interpret or apply state laws unless there was a clear violation of constitutional rights involved. In this case, he believed no such violation existed and thus, it should have been left to Virginia's courts to decide whether their own laws were being properly applied in relation to property rights and inheritance issues at hand in this case. Furthermore, he disagreed with majority’s interpretation of Virginia law regarding marital property rights and felt they had misapplied these rules in reaching their decision.