In the Meehan v. Valentine case of 1891, the U.S Supreme Court ruled on a dispute over land ownership in California. The plaintiff, Meehan, claimed that he had purchased land from an individual who had received it as part of a Mexican Land Grant before California became part of the United States. However, this grant was not confirmed by Congress until after his purchase. Meanwhile, Valentine argued that he owned the same piece of property under a patent issued to him by the United States government after Congress confirmed the original grant's validity. The court held that even though Meehan bought and occupied his portion before Congressional confirmation occurred; it did not give him legal title to those lands because at that time they were still public lands belonging to America and could only be disposed according to its laws. Therefore, since Valentine’s patent came directly from federal authorities following due process (Congressional approval), it took precedence over any previous private transactions involving these territories. This decision reinforced two principles: firstly confirming congressional authority over public lands disposal and secondly emphasizing respect for due process when transferring titles between parties.

In the dissenting opinion for Meehan v. Valentine, it was argued that the majority's decision to uphold a law prohibiting non-residents from oyster dredging in Maryland waters violated the Privileges and Immunities Clause of Article IV of the Constitution. The dissent contended that this clause guarantees citizens of each state all privileges and immunities granted to citizens in other states, including economic pursuits such as oyster dredging. They believed that by upholding Maryland's law, they were allowing one state to discriminate against residents from another state which is contrary to constitutional principles promoting interstate harmony. Furthermore, they disagreed with the majority’s interpretation of Corfield v Coryell (1823), arguing instead that it established a broader protection for out-of-state individuals seeking employment or business opportunities within another state.