In Zimmerman v. Harding (1912), the U.S Supreme Court dealt with a dispute over land ownership in Kansas. The plaintiff, Zimmerman, claimed that he had purchased the land from its original owner and was therefore entitled to it. However, the defendant, Harding, argued that he had acquired rights to the property through adverse possession - a legal principle allowing someone who has occupied or used another's property for an extended period of time without being challenged by the rightful owner to claim title to it. The lower court ruled in favor of Zimmerman but on appeal this decision was reversed by the state supreme court which held that Harding indeed gained ownership via adverse possession as he openly cultivated and improved upon said lands for more than 15 years without any objection from anyone including Zimmerman himself who only sought action after such period elapsed.

In the dissenting opinion for Zimmerman v. Harding, it was argued that the majority's decision to uphold a law prohibiting non-residents from hunting game in Pennsylvania violated the Privileges and Immunities Clause of Article IV of the Constitution. The dissenting justices believed that this clause guaranteed citizens of each state all privileges and immunities granted to citizens in other states, including hunting rights. They contended that while states have power over their natural resources, they cannot discriminate against out-of-state residents by denying them access to these resources under equal terms as those enjoyed by its own residents. Therefore, they disagreed with upholding a law which they saw as discriminatory towards non-residents.