In the 1890 Supreme Court case Handley v. Stutz, a dispute arose over land in California that was originally granted by Mexico to two citizens before it became part of the United States. The plaintiffs claimed ownership based on an alleged transfer from one of those original grantees, while defendant Stutz asserted his title through a patent issued by the U.S government after proceedings under federal law governing lands acquired from Mexico. The court ruled in favor of Stutz, holding that once such lands have been confirmed and patented according to U.S law, they cannot be challenged on any grounds derived from Mexican grants or laws prior to cession. This decision affirmed the supremacy and finality of federal procedures for determining valid land titles following territorial acquisitions.

In the dissenting opinion for Handley v. Stutz, it was argued that the majority's decision to uphold a lower court ruling in favor of an individual who had purchased land at a tax sale failed to adequately consider the rights of the original property owner. The dissenting justices contended that there were serious questions about whether proper notice had been given before the tax sale took place and if due process was followed. They believed that these issues should have been more thoroughly examined before stripping someone of their property rights based on unpaid taxes. Furthermore, they disagreed with how easily one could lose their property under such circumstances and felt this case set a dangerous precedent for future cases involving similar situations.