In the case of Cameron v. United States in 1892, the Supreme Court ruled on a dispute over land ownership in Arizona. The plaintiff, Colin Cameron claimed that he had acquired rights to certain lands under preemption and homestead laws before they were included within an Indian reservation by executive order. He argued that his claims should be recognized despite this subsequent inclusion within reservation boundaries. However, the U.S government contended that these lands were part of public domain and thus subject to disposition by executive authority for use as Indian reservations. The court sided with the government's argument stating that even if Cameron had initiated valid claims under preemption or homestead laws prior to their inclusion within reservation boundaries, such actions did not remove those lands from public domain nor limit federal power over them. Therefore, it was held lawful for these lands to be set aside as an Indian Reservation through presidential proclamation without recognizing any private claimant’s rights who may have initiated but not completed acquisition procedures at time of its establishment.

In the dissenting opinion for Cameron v. United States, Justice Brewer argued that the government had no right to claim ownership of land in Arizona previously granted by Mexico to a private citizen before it became U.S. territory. He believed that when the U.S acquired new territories, it also inherited pre-existing property rights and obligations established under prior sovereigns unless explicitly negated by Congress. In this case, he pointed out there was no such explicit negation from Congress regarding Mexican land grants in Arizona Territory after its acquisition through Gadsden Purchase Treaty of 1853. Therefore, according to him, these lands should have been recognized as privately owned rather than public domain available for homesteading or other disposition by federal authorities.