In the case of Brown et al. v. United States in 1923, the Supreme Court ruled on a dispute over land ownership rights between private citizens and the federal government. The plaintiffs were descendants of an individual who had been granted land by Spain before Florida became part of the U.S., while defendant was the U.S. government which claimed that it owned this property due to its acquisition from Spain under a treaty in 1819. The court held that when territory is transferred from one sovereign to another, pre-existing private property rights are generally respected unless explicitly revoked by new governing authority or through subsequent legal action such as condemnation proceedings or adverse possession claims; thus, ruling in favor of plaintiffs' claim for title based on their ancestor's Spanish grant against US Government’s assertion that it acquired clear title upon taking control over Florida without recognizing any prior grants made by Spain.

In the dissenting opinion for Brown et al. v. United States, Justice Oliver Wendell Holmes Jr., joined by Justice Louis Brandeis, argued that the defendants' actions were justified under a doctrine of self-defense and thus they should not have been convicted of murder. He contended that when faced with an imminent threat to one's life or safety, it is unreasonable to expect someone to weigh their options carefully before acting in self-defense; rather, they are likely to act on instinct and fear. Therefore, he believed that the law should reflect this reality and allow for such reactions as part of a valid claim of self-defense. Furthermore, he disagreed with the majority's interpretation of retreat laws - arguing instead that there was no legal duty for individuals threatened within their own homes (or "castles") to retreat before using deadly force against intruders if necessary.