In the Brown v. United States case of 1894, the Supreme Court ruled on a dispute over land ownership in Texas. The plaintiff, Brown, claimed that he was entitled to certain lands under an old Spanish grant which had been recognized by both Mexico and the U.S., but later sold to him by those who inherited it. However, these lands were already occupied and used by other people who believed they legally owned them based on their own purchases from different sources. The court held that even if there was validity in Brown's claim about his entitlement to these lands due to the Spanish grant recognition, this did not automatically invalidate all subsequent transactions involving this property made in good faith without knowledge of such prior claims or rights. Therefore, those currently occupying and using these disputed lands could not be dispossessed simply because of some ancient title whose existence they were unaware when making their own purchases.

In the dissenting opinion for Brown v. United States, Justice Brewer argued that the majority's decision to uphold a conviction based on circumstantial evidence was flawed. He believed that there were too many uncertainties and possibilities in this case to definitively conclude guilt beyond reasonable doubt. The defendant was accused of stealing mail bags from a train station, but no one witnessed him committing the crime or saw him with stolen goods afterward. Instead, he was found near the scene with tools capable of breaking into mail bags and had previously been seen at another station where similar thefts occurred. While these facts might arouse suspicion, they do not conclusively prove his guilt according to Justice Brewer who insisted on direct evidence as necessary for such serious charges.