In the case of Albright v. Sandoval in 1909, the United States Supreme Court ruled on a dispute involving land ownership rights in New Mexico. The plaintiff, Albright, claimed that he had purchased a tract of land from an individual who had received it as part of a Spanish land grant before New Mexico became part of the U.S., and therefore his claim was valid under international law. However, defendant Sandoval argued that this sale was invalid because at the time it took place, only communal property rights existed for this type of grant; individual parcels could not be sold separately without approval from all members of the community or their legal representatives. The court sided with Sandoval's interpretation and held that under Mexican law (which still applied to these grants), lands were owned communally by all residents within certain boundaries rather than being divided into individually-owned lots. Therefore any sales made without collective consent were voided when New Mexico became U.S territory due to provisions in its treaty with Spain preserving existing property arrangements.

The dissenting opinion in the case of Albright v. Sandoval argued that the majority's decision was inconsistent with previous rulings and infringed upon individual rights. The dissenting justices believed that the court had overstepped its boundaries by ruling on an issue not directly related to federal law or constitutionality, but rather a matter of state jurisdiction. They contended that it was inappropriate for the Supreme Court to intervene in New Mexico's internal affairs when there were no clear violations of constitutional rights involved. Furthermore, they expressed concern about potential negative implications this could have on future cases involving tribal sovereignty and self-governance issues among Native American tribes within U.S states' borders.