In the 1910 case of Weyerhaeuser v. Hoyt, the United States Supreme Court dealt with a dispute over timberland ownership in Washington state. The plaintiff, Frederick Weyerhaeuser, claimed that he had purchased land from the Northern Pacific Railroad Company which was granted to them by an Act of Congress in 1864. However, this claim was disputed by defendant William Hoyt who argued that the land had been reserved for public use under another Congressional Act passed earlier in 1853 and thus could not have been sold to Weyerhaeuser. The court ruled against Weyerhaeuser stating that when there is conflict between two Acts of Congress regarding land grants or reservations, preference should be given to preserving lands for public use rather than private acquisition.

The dissenting opinion in the Weyerhaeuser v. Hoyt case argued that the government had no right to impose a tax on property owned by American citizens abroad, as it was not within its jurisdiction. The dissenters believed that this action violated constitutional principles and infringed upon individual rights. They contended that such an imposition of taxes could potentially lead to double taxation if foreign governments also decided to tax these properties, which would be unfair for American citizens living abroad. Furthermore, they expressed concerns about the potential implications of this ruling on international relations and diplomacy, arguing it might provoke retaliatory actions from other countries whose nationals own property in America.