The U.S. Supreme Court case Catholic Bishop of Nesqually v. Gibbon, 1894, revolved around a land dispute in the state of Washington between the Catholic Church and an individual named James Gibbon. The church claimed ownership over certain lands under a Mexican land grant that predated American sovereignty over the area while Gibbon argued his title was valid based on legislation passed by Congress after it gained control over these territories. The court ruled in favor of Mr. Gibbon, stating that although international law generally respects existing property rights when territory changes hands between nations, this principle does not apply to uncultivated lands held for speculative purposes or future use as opposed to actual settlement or improvement at the time of transfer; such properties are deemed part of public domain subject to disposal by new sovereign according its laws and policies.

In the dissenting opinion for Catholic Bishop of Nesqually v. Gibbon, it was argued that the majority's decision failed to adequately consider and respect the rights of religious institutions in property disputes. The dissent emphasized that under U.S law, churches have a right to manage their own affairs without interference from civil authorities unless there is clear evidence of fraud or collusion. In this case, they believed no such evidence existed against the church. They also pointed out inconsistencies in how laws were applied by highlighting cases where secular organizations were given more leeway than religious ones in similar situations. Furthermore, they criticized the majority for not fully understanding or appreciating canon law and its role within Catholic Church governance structures which led them to misinterpret key facts about how church properties are managed and controlled.