In the case of Interstate Land Company v. Maxwell Land Grant Company, 1890, the U.S Supreme Court was tasked with determining whether a land grant made by Mexico to private individuals before it ceded territory to the United States under the Treaty of Guadalupe Hidalgo in 1848 remained valid. The dispute arose when both companies claimed ownership over a large tract of land in New Mexico and Colorado. The Interstate Land Company argued that they had acquired title from those who purchased it at public auction after it was seized for non-payment of taxes while Maxwell Land Grant Company maintained their claim based on an original Mexican land grant which had been confirmed by Congress in 1860. In its decision, the court upheld Maxwell's claim stating that once Congress confirms such grants, they are immune from attack or inquiry into their validity even if there were irregularities or fraud involved initially. This ruling affirmed respect for property rights established under previous sovereigns and highlighted how international treaties can impact domestic law.

The dissenting opinion in the case of Interstate Land Company v. Maxwell Land Grant Company argued that the majority's decision was based on a misinterpretation of both law and fact. The dissenters believed that the original grant from Mexico to Beaubien and Miranda, which formed the basis for Maxwell's claim, did not include certain lands claimed by Interstate. They contended that these lands were public domain at the time New Mexico became part of United States territory following Mexican-American War, thus making them available for homesteading under U.S laws. Furthermore, they disagreed with majority’s interpretation of 1860 Act confirming Beaubien-Miranda grant as including those disputed lands; instead arguing it merely confirmed whatever rights existed under original Mexican grant without expanding them further. In their view, this meant any ambiguity about what land was included should be resolved against Maxwell rather than presuming Congress intended to give away more public land than necessary.