The Fuller court was no stranger to criticism or controversy when it came to interpreting law or the Constitution. For example, Justice Brewer for the court laid down a bizarre doctrine that said it was “immaterial” how one obtains property: “He may have made his fortune by dealing in slaves, as a lobbyist, or in any other way obnoxious to public condemnation; but, if he has acquired the legal title to his property, he is protected in its possession, and cannot be disturbed until the receipt of the actual cash value.”

Only the mafia (or a railroad magnate) could appreciate this kind of logic.

In the cases of Brooks vs. Codman, and Foote v. Women’s Board of Missions where the court stepped in to revise an act of Congress that was standing in the way of making Justice Horace Gray a wealthy man. Codman was the administrator of Justice Gray’s grandfather’s (William) estate and under a 1891 law payments from the estate could only go to “creditors, legatees, assignees or strangers to the blood.”

What did the court do? They did just as they have done before, and what they had done in Wong Kim Ark, they simply said Congress did not mean what it said, and instead, meant “next of kin.” Who was William Gray’s “next of kin”? None other than Justice Gray himself.

http://federalistblog.us/2006/12/us_v_wong_kim_ark_can_never_be_considered.html