The U.S. Supreme Court case Guaranty Title & Trust Corporation, Receiver of Vue De L'eau Company v. United States in 1923 revolved around a dispute over land ownership and the validity of certain patents issued by the government. The Vue De L'eau Company claimed that it had been granted valid title to several parcels of land under swamp-land grants given by Congress to Louisiana in 1849 and subsequent patents from the state. However, these lands were later declared public lands by an Executive Order in 1912 due to their inclusion within a bird reservation. The company filed suit against this order but lost at both district court level and on appeal before bringing its case to the Supreme Court. The main issue was whether or not these swamp-land grants could be invalidated retroactively if they were found not actually to have been swamp lands when surveyed for patenting purposes - something which would make them ineligible for such grants under federal law. In its decision, the Supreme Court sided with lower courts' rulings that indeed they could be invalidated retrospectively if proven incorrect upon surveying; thus upholding executive power over public land management while also affirmatively asserting judicial review's role even where administrative decisions about property rights are concerned.

In the dissenting opinion for Guaranty Title & Trust Corporation v. United States, Justice McReynolds disagreed with the majority's interpretation of the law and its application to this case. He argued that Vue de L'eau Company had not defaulted on its obligations under a contract with the government because it was prevented from fulfilling them due to an act of Congress which made performance impossible. The company was ready and willing to perform but could not do so legally after Congress passed legislation prohibiting further work on their project. Therefore, he believed that they should be entitled to recover damages from the government as compensation for their losses resulting from this situation. Furthermore, he contended that there were no grounds for holding Guaranty Title & Trust Corporation liable in this case since they merely acted as receivers appointed by a court order and did nothing wrong themselves.