In the case of Dickson v. Patterson, 1895, the United States Supreme Court was tasked with resolving a dispute over land ownership in Colorado. The plaintiff, Dickson, claimed that he had acquired valid title to certain lands under preemption laws and homestead acts by fulfilling all necessary conditions such as settlement and cultivation. However, these lands were also claimed by Patterson who asserted his rights based on an older Mexican grant which was confirmed by Congress after Dickson's alleged acquisition. The court ruled in favor of Patterson stating that when Congress confirmed the old Mexican grants it intended to confirm them absolutely without any encumbrances or claims arising from subsequent settlements or improvements made on those lands prior to confirmation date. Therefore, even though Dickson may have fulfilled all requirements for acquiring title under preemption laws and homestead acts before Congressional confirmation of Mexican grant took place; his claim could not supersede Patterson’s right derived from this earlier grant.

In the dissenting opinion for Dickson v. Patterson, the justice argued that the majority's decision was inconsistent with previous rulings and interpretations of bankruptcy law. The dissent took issue with how the court interpreted "fraud" in this case, arguing that it should not include cases where a debtor honestly believed they would be able to repay their debts when they incurred them. They also disagreed with how much weight was given to state laws over federal ones in determining whether or not a debt could be discharged through bankruptcy. Furthermore, they criticized what they saw as an overly broad interpretation of which assets could be seized by creditors during bankruptcy proceedings.