In the 1891 case of Felix v. Patrick, the United States Supreme Court dealt with a dispute over land ownership in California. The plaintiff, Felix, claimed that he had purchased a plot of land from an individual who had received it as part of a Mexican Land Grant before California became part of the U.S., and thus his claim was valid under the Treaty of Guadalupe Hidalgo which ended the Mexican-American War and required respect for such grants. However, this grant was never confirmed by Congress or any commission established to review these claims after California's admission to statehood. The defendant, Patrick, argued that he obtained title through purchase from another party who acquired it via public auction due to unpaid taxes on said property by previous owners including Felix himself. The court ruled in favor of Patrick stating that even if there were errors during tax sale proceedings they would not invalidate subsequent transfers unless those errors were jurisdictional (pertaining to authority). It also held that since no action was taken within statutory period following tax sale regarding alleged irregularities; all objections are waived making current holder’s title absolute against prior owner’s claims regardless whether original assessment/taxation/sale might have been voidable at inception.

The dissenting opinion in the Felix v. Patrick case argued that the majority's decision was a departure from established legal principles, particularly those related to property rights and contracts. The dissent emphasized that under common law, an individual has a right to sell their property freely unless there is explicit legislation prohibiting such action. In this case, they believed no such prohibition existed and thus disagreed with the majority's interpretation of state laws regarding land sales for tax delinquency purposes. They also expressed concern about potential negative implications on contract law because it could undermine confidence in contractual agreements if courts can retroactively invalidate them based on new interpretations of existing laws or regulations.