In the case of Colburn v. Grant in 1900, the United States Supreme Court dealt with a dispute over land ownership. The plaintiff, Colburn, claimed that he had purchased a piece of property from an individual who had obtained it through preemption rights under federal law. However, before this person could receive official title to the land from the government, they sold it to Colburn. Meanwhile, another party named Grant also laid claim to this same parcel of land by virtue of having made improvements on it and filed for homestead rights after purchasing it at public auction when no one else bid on it. The court ruled in favor of Grant stating that his claim was superior because he followed proper procedure as outlined by federal law regarding acquiring property via homesteading - which included living on and improving upon said property for five years prior to filing a claim; whereas Colburn's seller did not follow due process required for preemptive claims (which would have involved residing on and cultivating said land). Therefore despite paying money for what he thought was rightfully his purchase based off someone else’s preemptive right – without them fulfilling their obligations first – meant that ultimately his purchase was invalid.

The dissenting opinion in the case of Colburn v. Grant disagreed with the majority's decision to uphold a lower court ruling that denied Colburn his claim on land he had purchased from an individual who did not have legal title to it. The dissent argued that, while it was true that the original seller did not have legal title at the time of sale, he later obtained valid ownership and should therefore be able to transfer this rightful ownership to Colburn. They contended that denying Colburn his claim would unjustly enrich Grant, who acquired title after him but without any payment or effort. Furthermore, they believed there were no statutory provisions barring such retroactive validation of sales made by individuals who subsequently acquire lawful titles. Thus, they felt equity demanded recognition of Colburn's rights as a bona fide purchaser for value and urged reversal of judgment against him.