In the case of French v. Carter in 1890, the US Supreme Court ruled on a dispute over land ownership. The plaintiff, French, claimed that he had purchased land from an individual who had obtained it through a patent issued by the United States government. However, this claim was disputed by Carter who argued that he held rightful title to the property based on a pre-existing Spanish grant which predates any American claims and should be recognized under terms of Treaty of Guadalupe Hidalgo (1848). The court sided with Carter stating that his rights were protected under international law as well as U.S domestic law because when America acquired California from Mexico via treaty obligations they agreed to respect all existing property rights at time of acquisition.

In the dissenting opinion for French v. Carter, Justice Lamar disagreed with the majority's decision to uphold a lower court ruling that allowed a land grant by Congress to be used for mining purposes. He argued that such grants should only be used for agricultural purposes unless explicitly stated otherwise in legislation. According to him, this interpretation was consistent with previous rulings and Congressional intent when passing these laws. Furthermore, he contended that allowing mining on these lands could lead to environmental damage and potential conflicts between miners and farmers over land use rights. Therefore, he believed it was necessary for the Court to interpret these laws narrowly in order not only protect natural resources but also prevent future legal disputes.