In the United States v. Dumas case of 1892, the Supreme Court ruled on a dispute involving land ownership in Louisiana. The plaintiff, the U.S government, claimed that it owned certain lands under an act passed by Congress in 1824 which granted rights to occupants who had settled before January 20th, 1818. However, defendant Dumas argued that he held rightful title to these lands through Spanish grants issued prior to this date and thus predating American jurisdiction over Louisiana territory following its purchase from France in 1803. The court found in favor of Dumas based on evidence presented showing valid Spanish land grants were indeed given before America's acquisition of Louisiana and therefore should be honored as per international law principles regarding property rights upon territorial changes between nations.

In the dissenting opinion for United States v. Dumas, Justice Brewer argued that the court should not have jurisdiction over this case as it involved a dispute between private parties rather than a matter of public concern. He contended that while Congress had granted certain powers to federal courts in territories, these did not extend to all civil cases but were limited to those involving federal law or constitutional issues. In his view, allowing federal courts in territories such broad jurisdiction would undermine state sovereignty and disrupt the balance of power between states and the federal government. Furthermore, he disagreed with majority's interpretation of Congressional intent behind territorial judiciary acts which according him was never meant to grant such expansive authority over purely local matters.