In the 1910 case of Herencia v. Guzman, the United States Supreme Court dealt with a dispute over property rights in California that originated from Spanish and Mexican land grants before California became part of the U.S. The plaintiff, Herencia, claimed ownership based on an old Spanish grant while defendant Guzman's claim was based on a more recent purchase from another party who had received it through succession from Mexico after its independence but before American acquisition. The court ruled in favor of Guzman stating that under international law and treaties between nations (in this case Treaty of Guadalupe Hidalgo), changes in sovereignty do not affect private property rights unless explicitly stated by the new sovereign power or if there is explicit refusal to recognize those rights by competent authority. Therefore, since neither condition applied here as US government did not interfere with these titles after acquiring California nor refused recognition to them; hence they remained valid.

The dissenting opinion in the case of Herencia v. Guzman argued that the majority's decision was inconsistent with established principles of international law and violated the rights of foreign citizens. The dissenting justices believed that a Spanish will, executed in Cuba, should be recognized as valid under U.S. law because it complied with all necessary formalities required by Spanish law at the time it was written. They contended that refusing to recognize this will would undermine respect for foreign legal systems and could potentially harm U.S.-foreign relations by suggesting an unwillingness to honor foreign laws and customs. Furthermore, they suggested that such refusal might also infringe upon individual property rights by denying individuals their rightful inheritances based on technicalities rather than substantive issues related to validity or intent.