The U.S. Supreme Court case Albright v. Territory of New Mexico ex rel. Sandoval in 1905 revolved around a dispute over land ownership in the territory of New Mexico, which was not yet a state at that time. The plaintiff, Albright, claimed that he had purchased the disputed property from its original owner and thus held rightful title to it under federal law governing territories. However, the defendant - represented by Sandoval - countered this claim by arguing that local territorial laws should apply instead because they were more specific about property rights within their jurisdiction than general federal statutes were for all territories collectively. Ultimately, the court sided with Albright's argument and upheld his right to own the contested land based on his purchase from its previous owner as recognized under applicable federal law.

In the dissenting opinion for Albright v. Territory of New Mexico ex rel. Sandoval, Justice Harlan argued that the majority's decision was inconsistent with previous rulings and violated principles of federalism. He contended that it was not within the jurisdiction of a federal court to interfere in matters pertaining to state law unless there were constitutional issues at stake or if a state court had made an egregious error in applying its own laws. In this case, he saw no such violation or error; rather, he believed that the majority had overstepped its bounds by intervening in what should have been strictly a matter for local courts to decide upon based on their interpretation of territorial law. Furthermore, Justice Harlan expressed concern about potential negative implications this ruling could have on future cases involving similar circumstances where states' rights might be undermined by unwarranted federal interference.