In the 1905 case of Lincoln v. United States, the Supreme Court ruled on a dispute over land ownership in California. The plaintiff, Lincoln, claimed that he had purchased land from an individual who held a Spanish land grant confirmed by Congress and patented by the President. However, it was discovered that this patent did not include all of the original Spanish grant's lands due to errors made during surveying processes prior to its issuance. As such, some parts were left out and later sold as public lands by the U.S government which ended up with defendant - United States. The court decided in favor of the U.S government stating that once a patent has been issued after confirmation of a claim under an old Mexican or Spanish grant (as per Treaty of Guadalupe Hidalgo), it is conclusive evidence against all parties except for those claiming under subsequent grants from federal authorities; even if there are mistakes within said patents' descriptions or boundaries. Therefore, any parcels mistakenly omitted from these patents become part of public domain available for sale by U.S Government unless legal action is taken before such sales occur.

In the dissenting opinion for Lincoln v. United States, Justice Harlan disagreed with the majority's decision to uphold a lower court ruling that allowed federal authorities to seize and sell property owned by a debtor who had failed to pay taxes. He argued that this violated the Fifth Amendment, which protects individuals from being deprived of their property without due process of law. Harlan contended that seizing and selling someone's property without giving them an opportunity to challenge the seizure in court was not due process. Furthermore, he believed it was unfair for federal authorities to be able to seize someone's entire estate just because they owed taxes on part of it. In his view, only those assets necessary to satisfy the tax debt should have been seized.