The U.S. Supreme Court case Lane v. Darlington centered around a dispute over land ownership in the state of California, which was originally granted by Mexico to private individuals before California became part of the United States. The Secretary of Interior, Franklin K. Lane, argued that these lands should be considered public domain and thus under federal control because they were not properly claimed according to Mexican law prior to American acquisition of the territory following the Treaty of Guadalupe Hidalgo in 1848. However, trustees for Clap's estate (Darlington et al.) held that their title was valid as it had been confirmed by an earlier court ruling and patent issued by President Lincoln in 1866. In its decision, the Supreme Court ruled against Lane and upheld previous rulings confirming Clap’s claim on this property based on Mexican grants made before California joined America as a state; hence such lands are not part of public domain but privately owned properties with rights protected under US laws.

In the dissenting opinion for Lane v. Darlington, Justice Holmes disagreed with the majority's decision that a land lease agreement between an Indian tribe and non-Indians required Congressional approval to be valid. He argued that such interpretation of the law was too broad and did not align with its original intent or historical application. According to him, Congress intended only to regulate sales of tribal lands, not leases. Furthermore, he pointed out that historically many similar agreements had been made without Congressional approval and were considered valid by all parties involved including federal authorities overseeing Indian affairs. Therefore, he believed it was incorrect for the court to retroactively invalidate these contracts based on a new interpretation of existing laws which could potentially disrupt established practices and expectations in dealing with Native American tribes' property rights.