In the 1895 case of Lucas v. United States, the U.S. Supreme Court ruled on a dispute involving land ownership in Texas. The plaintiff, Lucas, had purchased land from an individual who claimed to have received it as part of a Mexican grant before Texas became part of the United States. However, after purchasing and improving upon this property for several years, another party also laid claim to this same piece of land based on a separate title issued by the state government after annexation into America. The court was tasked with determining which title held precedence: one granted under Mexican rule or one granted by American authorities post-annexation? In its decision, the court upheld that titles given out by Mexico prior to annexation were valid if they met certain conditions set forth in legislation passed at both federal and state levels following Texas's incorporation into America. Therefore since Lucas' predecessor-in-interest did not meet these requirements (namely filing their claim within specified time limits), his title was deemed invalid against subsequent grants made by American authorities - thus ruling in favor of defendants who held such later-granted titles.

In the dissenting opinion for Lucas v. United States, Justice Harlan argued that the majority's decision was inconsistent with previous rulings of the court and violated principles of federalism by allowing a state law to supersede federal authority. He contended that Congress had exclusive power over interstate commerce and thus any state laws conflicting with this power should be deemed unconstitutional. In his view, Louisiana's lottery statute interfered directly with commercial intercourse among states as it prohibited transportation of lottery tickets from other states into Louisiana. Therefore, he believed it was within Congress' jurisdiction to regulate such activities under its constitutional powers related to interstate commerce. Furthermore, he disagreed with the majority’s interpretation that only 'goods' could be regulated under these powers; instead arguing that they extended to all articles or commodities including lottery tickets which are subjects of traffic and therefore partake in nature of merchandise.