In the case of Arivaca Land and Cattle Company v. United States in 1901, the Supreme Court ruled on a dispute over land ownership between a private company and the federal government. The Arivaca Land and Cattle Company claimed that it had purchased lands from Mexico before they were ceded to the U.S., thus making them rightful owners under Mexican law. However, these claims were not recorded until after this territory became part of Arizona following Gadsden Purchase in 1853. The court held that because there was no evidence showing that these purchases were made prior to American acquisition or any proof of possession during Mexican rule, their claim could not be upheld under Article VIII of Treaty with Mexico (1848). Furthermore, even if such evidence existed, it would still have been necessary for them to present their claim within one year as required by an Act passed by Congress in 1862 which they failed to do so. Therefore, the Supreme Court affirmed lower courts' decisions rejecting Arivaca's claims thereby ruling in favor of United States.

The dissenting opinion in the case of Arivaca Land and Cattle Company v. United States argued that the majority's decision to uphold a lower court ruling, which invalidated a land grant made by Mexico prior to its cession of territory to the U.S., was incorrect. The dissent contended that there was sufficient evidence showing that Mexican authorities intended for this land grant to be valid, including documents indicating such intent and actions taken by grantees consistent with ownership rights. It also pointed out inconsistencies in how similar cases had been handled previously, arguing for more uniform application of precedent regarding these types of territorial disputes. Furthermore, it criticized the majority's reliance on technicalities related to documentation rather than considering broader historical context and principles of justice when making their determination.