In the case of Wright-Blodgett Company v. United States (1914), the U.S Supreme Court ruled in favor of the United States, upholding a lower court's decision that timberland purchased by Wright-Blodgett was rightfully reclaimed by the government due to fraudulent procurement. The company had acquired land under an act allowing for purchase and settlement of forest lands not suitable for cultivation, but it was later discovered that they misrepresented facts about its suitability for farming purposes. The company argued that even if fraud occurred during acquisition, their subsequent good faith improvements on this property should protect them from forfeiture. However, Justice Holmes delivered the opinion stating there is no principle where a trespasser can gain rights over public property through improvements made in bad faith or ignorance.

In the dissenting opinion for Wright-Blodgett Company v. United States, Justice Holmes disagreed with the majority's interpretation of the Act of March 3, 1891. He argued that this act did not intend to grant a right to purchasers to cut timber on land before it was classified as "more valuable for its timber or stone than for agricultural purposes." Instead, he believed that such rights were only granted after classification had occurred. Furthermore, he contended that even if such rights were granted prior to classification, they should be considered void because they would contradict other laws preventing premature cutting and destruction of forests on public lands. Thus, in his view, the plaintiff company could not claim any valid title or right under their purchase contract since no proper classification had been made at the time when they bought and began logging operations on these lands.