In the case of Cheney v. Hughes, 1890, the United States Supreme Court dealt with a dispute over land ownership in California. The plaintiff, Cheney, claimed that he had purchased the property from an individual who had acquired it under a Mexican land grant before California became part of the US. However, this claim was disputed by Hughes who argued that he owned the property through purchase from another party after California's admission to statehood. The court ruled in favor of Hughes stating that any title derived from Mexican grants could only be validated by presenting them to a board of commissioners for confirmation within two years following passage of an act passed on March 3rd 1851 - something which Cheney failed to do. Therefore his claim was invalid and Hughes' title stood.

The dissenting opinion in the case of Cheney v. Hughes argued that the majority's decision to uphold a lower court ruling, which found that a certain land grant did not extend to include mineral rights, was incorrect. The dissenters believed that the original intent of Congress when granting this land was indeed to include such rights. They pointed out inconsistencies in how similar cases had been handled previously and suggested that there should be more uniformity in interpreting these types of grants from Congress. Furthermore, they contended that denying mineral rights could potentially discourage future development and investment on these lands due to uncertainty over what exactly is included within them.