In the case of Christopher v. Norvell, 1905, the United States Supreme Court ruled on a dispute involving land ownership in Texas. The plaintiff, Christopher, claimed that he had purchased a tract of land from an individual who had received it as part of a Spanish grant before Mexico gained independence. However, after Texas became independent and later joined the U.S., its government sold this same parcel to another party (Norvell), arguing that all unclaimed lands within its borders were now state property. The court held that under international law principles recognized by both Spain and the U.S., any valid grants made by Spain remained effective even after changes in sovereignty over territory where such lands were located unless explicitly nullified by new sovereigns' laws or actions; hence they could not be treated as "unclaimed" lands subject to sale or other disposition by subsequent governments without violating original grantees' rights protected under treaties between nations involved in these territorial transfers.

In the dissenting opinion for Christopher v. Norvell, it was argued that the majority's decision failed to adequately consider and respect state law. The dissenting justices believed that the case should have been decided based on Texas law, which they felt clearly supported Mr. Christopher's claim of ownership over a piece of property in dispute with Mrs. Norvell. They contended that under Texas law, an individual who has openly possessed and used a property for ten years or more without any legal challenge from others can gain rightful ownership of said property through "adverse possession." In this case, Mr. Christopher had lived on and maintained the disputed land for well over ten years before Mrs. Norvell made her claim to it; thus according to Texas' adverse possession laws he should be considered its lawful owner regardless of whether or not he held formal title deeds to it at first.