In the case of Boquillas Land and Cattle Company v. Curtis, 1908, the U.S. Supreme Court was tasked with determining whether a land grant made by Mexico prior to its cession of territory to the United States under the Treaty of Guadalupe Hidalgo in 1848 was valid under American law. The Boquillas Land and Cattle Company claimed ownership over certain lands based on this Mexican land grant given to their predecessors in interest before Texas became part of America. However, John M.Curtis had been granted a patent for these same lands from the State of Texas after it joined Union. The court ruled that while such grants were generally respected following territorial acquisition if they were finalized before cession, this particular claim failed because there wasn't sufficient evidence proving that all necessary steps required by Mexican law had been completed for finalizing this grant prior to cession date i.e., February 2nd, 1848. Therefore,the decision favored Curtis as he held his title through an American source (State Of Texas), which took precedence over any incomplete foreign claims.

In the dissenting opinion for Boquillas Land and Cattle Company v. Curtis, it was argued that the majority's decision failed to properly consider the nature of Spanish land grants in Texas. The dissenting justices believed that these grants should be viewed as complete transfers of property rights from Spain to private individuals, rather than mere concessions or licenses subject to later revocation by Mexico or Texas. They contended that under international law principles recognized at the time of Mexican independence and Texas' annexation by the United States, such pre-existing property rights should have been respected. Therefore, they disagreed with majority’s view which held that a grant made by Spain could be invalidated due to non-compliance with conditions imposed after Mexican independence. This interpretation according to them undermined stability in land titles derived from Spanish grants and contradicted historical practice regarding recognition of foreign-granted property rights upon territorial changes.