In the 1916 case of Board of Trustees of the Sevilleta de la Joya Grant v. Board of Trustees of the Belen Land Grant, a dispute arose over land ownership in New Mexico. The Sevilleta de la Joya Grant claimed that they were entitled to certain lands under an old Spanish grant which had been confirmed by Congress but not yet surveyed or partitioned. Meanwhile, the Belen Land Grant argued that they held rightful title to these lands through prior possession and use dating back several decades before New Mexico's statehood. The Supreme Court ruled in favor of the Belen Land Grant, stating that their longstanding possession and use established a valid claim to ownership under U.S law despite any potential conflicting claims from unsurveyed Spanish grants.

The dissenting opinion in the case of Board of Trustees of the Sevilleta de la Joya Grant v. Board of Trustees of the Belen Land Grant argued that there was a lack of substantial evidence to support the majority's decision. The dissenting justices believed that, while it is true that Spanish and Mexican land grants were generally respected by U.S law after territories were acquired from Mexico, this particular grant did not meet all necessary criteria for recognition under American jurisprudence. They contended that no clear title or possession had been established by plaintiffs and thus they should not be entitled to claim ownership over disputed lands based on an ambiguous historical document alone. Furthermore, they expressed concern about setting a precedent where vague claims could potentially disrupt settled property rights without compelling proof.