In the 1890 case of Whitehead v. Shattuck, the U.S Supreme Court was tasked with resolving a dispute over land ownership in California. The plaintiff, Whitehead, claimed that he had purchased a piece of property from one Mr. Pioche and subsequently sold it to Shattuck who refused to pay for it on grounds that Pioche did not have valid title to sell the property initially. The court examined two main issues: whether or not Pioche held legal title at the time of sale and if so, whether this could be transferred effectively by him as an alien (non-citizen). After reviewing relevant statutes and precedents regarding land grants made during Mexican rule before California became part of United States territory, along with laws concerning aliens' rights to hold and transfer real estate within US jurisdiction; they ruled in favor of Whitehead stating that indeed Pioche had possessed good title which he legally transferred despite his status as an alien.

In the dissenting opinion for Whitehead v. Shattuck, it was argued that the majority's decision to uphold a lower court ruling - which held that an individual could not be prosecuted for selling liquor without a license if they were unaware of such requirement - undermined the principle of "ignorance of law excuses no one". The dissenting justices believed this created a dangerous precedent where individuals could avoid punishment simply by claiming ignorance. They also disagreed with the majority's interpretation of Connecticut’s liquor laws, arguing that these laws did not require knowledge or intent as elements necessary to establish guilt. Furthermore, they contended that allowing ignorance as defense would make enforcement nearly impossible and undermine public order and safety. Therefore, in their view, even though Mr. Shattuck may have been genuinely ignorant about needing a license to sell alcohol legally in Connecticut at the time he committed his offense; this should not absolve him from legal responsibility.