In the case of Lane, Secretary of the Interior, et al. v. Pueblo of Santa Rosa in 1918, the Supreme Court ruled on a dispute over land rights between Native American tribes and settlers backed by federal authorities. The Pueblo tribe claimed that they had been granted certain lands under Spanish rule before Mexico gained independence and these rights were protected when New Mexico was ceded to the United States after Mexican-American War. However, non-Native settlers argued that those grants did not constitute legal ownership under U.S law as it only recognized individual private property rights rather than communal tribal ones. The court sided with the Pueblos stating that their aboriginal title was valid even if it didn't conform to Anglo-American concepts of property ownership because treaties signed during annexation guaranteed respect for pre-existing land arrangements unless explicitly extinguished by Congress which hadn't happened in this case.

In the dissenting opinion for Lane, Secretary of the Interior, et al. v. Pueblo of Santa Rosa (1918), Justice Holmes argued that the majority's decision to uphold a land grant to the Pueblo tribe was based on an incorrect interpretation of Spanish law and its application in U.S. courts following Mexico's cession of territory under the Treaty of Guadalupe Hidalgo in 1848. He contended that while Spanish law did recognize communal property rights for indigenous tribes, it also allowed for these rights to be extinguished by royal decree or other governmental action without compensation - a principle not recognized by U.S. law regarding private property but applicable here due to historical context and precedent set by previous court decisions involving similar cases with Mexican land grants post-cession.