In the case of Woodward v. De Graffenried (1914), the U.S Supreme Court dealt with a dispute over land ownership and inheritance rights. The plaintiff, Woodward, claimed that he was entitled to certain lands in Mississippi based on an 1836 will from his ancestors. However, these lands were sold by administrators before they could be passed down to him. He argued that this sale was invalid because it violated his property rights under the Fourteenth Amendment due to lack of notice or opportunity for hearing before deprivation of property occurred. The defendant, De Graffenried, countered that she had purchased the land in good faith without knowledge of any potential claims against it and thus should not be penalized for actions taken by previous owners. The court ruled in favor of De Graffenried stating that while due process is required when government action deprives someone's property right directly; however if such deprivation occurs indirectly as a result of private transactions between individuals then no constitutional violation has occurred even if there might have been some procedural irregularities involved during those transactions.

In the dissenting opinion for Woodward v. De Graffenried, Justice Holmes disagreed with the majority's decision to uphold a lower court ruling that allowed an oil company to drill on leased land without compensating the lessor for damages caused by drilling operations. He argued that such a ruling was inconsistent with common law principles and unfairly favored corporations over individual property owners. According to Holmes, when a lease allows for extraction of minerals but does not explicitly provide immunity from liability for damage caused in doing so, it should be assumed that normal rules of responsibility apply. Therefore, he believed that unless specifically stated otherwise in their contracts, companies should be held accountable for any harm they cause while extracting resources from leased lands.