In Clark et al. v. Graham, the Supreme Court of the United States heard a case concerning an act passed by Congress in 1820 that allowed for the sale of public lands to settlers at $1.25 per acre or less and authorized surveyors to lay out townships on such land before it was sold. The plaintiffs argued that this violated their rights as citizens under Article I, Section 8 of the Constitution which grants Congress exclusive power over public lands and prohibits states from passing laws affecting them without congressional approval. The court ruled in favor of defendants, finding that while Congress had exclusive authority over public lands, they could delegate certain powers related to those lands to state legislatures so long as it did not interfere with federal law or policy regarding those same lands. This decision established a precedent allowing for greater cooperation between federal and state governments when dealing with matters related to public land ownership and management

In Clark et al. v. Graham, the Supreme Court was asked to decide whether a state law that allowed for the sale of public lands in order to fund education violated the Constitution's Contract Clause. The majority opinion held that it did not violate this clause because there was no contract between the state and any individual purchaser of land; thus, no vested rights were infringed upon by such a sale. However, Justice Johnson dissented from this decision on two grounds: firstly, he argued that individuals who had purchased land prior to passage of this law should have been given notice before their property could be sold; secondly, he asserted that these sales constituted an impairment of contracts since they interfered with existing expectations about how much money would be received from selling one's own property at market value. He concluded his dissent by stating "that if laws can be passed which shall take away or diminish private rights without compensation...the security which our constitution intended will fail."