In the 1900 case of Workman v. New York City, Mayor, Aldermen and Commonalty, the U.S Supreme Court dealt with a dispute over property rights. The plaintiff was William P. Workman who owned land in New York City that had been taken by the city under eminent domain laws for public use as part of a street expansion project. However, he claimed that his property was undervalued during this process and sought compensation for what he believed to be its true value. The court ruled against him stating that it did not have jurisdiction to review decisions made by state courts on matters concerning local or domestic law unless there is an alleged violation of federal rights involved in such cases which wasn't found here.

The dissenting opinion in the case of Workman v. New York City, Mayor, Aldermen and Commonalty argued that the majority's decision to uphold a city ordinance prohibiting street preaching without a permit was an infringement on religious freedom. The dissenters believed that this ruling gave too much power to local authorities to regulate or even suppress religious expression under the guise of maintaining public order. They contended that such ordinances could be used arbitrarily and capriciously by those in power to silence unpopular or minority religions. Furthermore, they pointed out that there were already laws against disturbing the peace which could be applied if a preacher's actions truly caused disruption or harm. Therefore, they saw no need for additional restrictions specifically targeting religious speech.