In the 1909 case Alvarez y Sanchez v. United States, the U.S Supreme Court ruled on a dispute involving property rights in California that dated back to Mexican rule. The appellants, Alvarez and Sanchez, claimed ownership of land under an old Spanish grant which was confirmed by the Board of Land Commissioners but later rejected by the District Court due to insufficient evidence supporting their claim. They appealed this decision arguing that they had been deprived of their property without due process as guaranteed by the Fifth Amendment. However, upon review, it was found that there were significant discrepancies between their original claim and what was presented at trial including differences in boundaries and acreage amounts leading to suspicion about its authenticity. The Supreme Court upheld the lower court's ruling stating that while Spanish grants should be respected under US law following acquisition of territory from Mexico via Treaty of Guadalupe Hidalgo (1848), such claims must still meet evidentiary standards for proof before being recognized legally.

In the dissenting opinion for Alvarez Y Sanchez v. United States, Justice Harlan argued that the majority's decision was inconsistent with previous rulings and principles of international law. He contended that a nation has no right to punish an individual for acts committed outside its territory unless such acts are directed against its security or rights. In this case, he believed there was no evidence showing that Alvarez y Sanchez had intended to violate U.S laws when they sold arms in Mexico. Furthermore, he pointed out inconsistencies in how the court applied jurisdictional rules; while it claimed jurisdiction over actions occurring on a foreign ship in international waters (based on nationality principle), it refused to apply this same rule when considering whether Mexican law could reach American citizens who violated their laws from within U.S borders (territoriality principle). This inconsistency undermined both fairness and predictability in legal proceedings.