In the case of Bond v. Unknown Heirs of Barela, 1912, the U.S Supreme Court dealt with a land dispute in New Mexico. The plaintiff, Bond, claimed ownership over certain lands based on a Mexican grant that was confirmed by Congress but never patented by the United States government. The defendants were alleged to be unknown heirs of one Barela who had received an overlapping Spanish grant which was also confirmed but not patented. The court ruled in favor of Bond stating that even though his title hadn't been perfected through patenting process from the US government after confirmation by Congress, it still held superiority over any adverse possession claim made under Spanish or Mexican grants unless those claims have been recognized and validated under US law as well.

The dissenting opinion in the case of Bond v. Unknown Heirs of Barela argued that the majority's decision was flawed because it failed to properly consider Spanish law, which should have been applied given that the land grant at issue was made when New Mexico was still a part of Spain. The dissent contended that under Spanish law, common lands were intended for communal use and could not be sold or transferred by any individual member of the community without consent from all members. Therefore, they believed that Mr. Bond did not legally acquire ownership over these lands simply through purchase from some individuals within this community as he claimed. They also pointed out inconsistencies in how evidence had been interpreted and evaluated throughout different stages of litigation, expressing concern about potential bias against non-English speakers involved in this case.