In the 1914 case of Gallardo y Seary v. Nobl, the U.S Supreme Court was tasked with deciding on a dispute involving land ownership in California. The plaintiff, Gallardo y Seary, claimed that they were entitled to certain lands under an old Spanish grant which had been confirmed by the United States Land Commission and later patented by the United States government. However, these claims were contested by Nobl who argued that he held valid title to these lands through purchase from previous owners who also possessed legal patents issued by the U.S government for this same property. The court ruled in favor of Nobl stating that once a patent has been issued it is conclusive evidence of superior title against all adverse claimants and cannot be challenged even if there are allegations or proof showing fraud or mistake during its issuance process unless such charges can be directly traced back to actions committed by federal officials involved in granting said patent.

In the dissenting opinion for Gallardo y Seary v. Nobl, it was argued that the court should not have jurisdiction over this case as it involved a dispute between two foreign citizens in a foreign country. The dissenting justices believed that U.S courts should refrain from intervening in such matters unless there is a clear violation of international law or treaty obligations. They also pointed out that by deciding on this case, the Supreme Court might inadvertently interfere with diplomatic negotiations and potentially strain relations with other countries. Furthermore, they expressed concern about setting a precedent where U.S courts could be used to settle personal disputes between foreigners who happen to reside temporarily in America.