In the case of California v. Holladay (1895), the U.S. Supreme Court dealt with a dispute over land ownership in California, which was originally granted by Mexico before it became part of the United States. The plaintiff, State of California, claimed that certain lands were swamp and overflowed lands and thus belonged to them under an Act of Congress passed in 1850 granting such lands to states for reclamation purposes. However, defendant Holladay argued he had valid title from a Mexican grant confirmed by US patent issued in 1874. The court ruled against California stating that when there is conflict between state claims based on federal swamp land grants and private claims based on earlier Spanish or Mexican grants confirmed by federal patents, priority must be given to those holding titles derived from Spanish/Mexican law as they are protected under the Treaty of Guadalupe Hidalgo (1848). This treaty ended the Mexican-American War ensuring property rights would be respected after territories changed hands.

The dissenting opinion in the case of California v. Holladay, 1895 was not specified by a particular justice but it disagreed with the majority's decision to uphold Holladay's land claim. The dissent argued that there were significant issues with how the original Spanish land grant was interpreted and applied under U.S law after California became part of America following the Mexican-American War. It contended that Holladay did not meet all necessary requirements for valid ownership under this interpretation, particularly regarding continuous possession and improvement of the property since receiving it from his predecessor-in-interest who obtained it through dubious means during a period when many such grants were being fraudulently issued or manipulated for personal gain. The dissent also criticized procedural aspects of how evidence was handled in lower courts which may have unduly influenced their rulings favoring Holladay.