In the 1913 U.S. Supreme Court case Alzua v. Johnson, the court ruled on a dispute involving property rights in California that had been granted by Mexican law prior to California's admission into the United States. The plaintiff, Alzua, claimed ownership of land under a grant from Mexico and sought to eject Johnson who was occupying it under a claim of adverse possession for more than five years before suit was brought against him. The main issue at hand was whether or not an action for recovery could be maintained without presenting evidence of title confirmed by Congress as required by an act passed in 1851 concerning private land claims in California. The Supreme Court held that while confirmation proceedings were pending before Congress or its tribunals, no action could be taken; but once those proceedings concluded with either confirmation or rejection of title claims, then actions based upon such titles may proceed according to general principles governing real property disputes. In this particular case since there had been no final determination regarding Alzua’s claim when he initiated his lawsuit against Johnson, his action failed.

In the dissenting opinion for Alzua v. Johnson, it was argued that the U.S. Supreme Court did not have jurisdiction over this case because it involved a matter of Philippine law and should be decided by their courts instead. The dissenting justices believed that the majority's decision to hear this case represented an inappropriate extension of American judicial power into foreign territories, which could potentially undermine local legal systems and infringe upon their sovereignty. They also disagreed with the majority's interpretation of international law in relation to property rights during wartime occupation, arguing that these laws were designed to protect civilians from harm rather than grant them new economic opportunities or advantages at others' expense.