In the case of Montoya and Unknown Heirs of Vigil v. Gonzales in 1913, the US Supreme Court was tasked with resolving a dispute over land ownership in New Mexico. The plaintiffs, Montoya and unknown heirs of Vigil, claimed they were rightful owners due to an old Spanish grant that predated American control over the territory. However, defendant Gonzales argued he had acquired valid title through adverse possession - a legal principle allowing someone to gain ownership if they have openly occupied and used it for a certain period without protest from the original owner. The court ruled in favor of Gonzales on account that even though there may have been an ancient grant as alleged by plaintiffs, their failure to exercise acts of ownership allowed for his claim under adverse possession laws.

In the dissenting opinion for Montoya and Unknown Heirs of Vigil v. Gonzales, Justice Holmes disagreed with the majority's decision to deny land rights to the plaintiffs based on a lack of evidence proving their ancestors' possession during Spanish rule. He argued that there was sufficient historical context suggesting that such ownership likely existed, even if specific documents were not available due to time or circumstance. Furthermore, he criticized the Court's reliance on strict legal formalities in interpreting old Spanish laws and customs which may have had different standards for establishing property rights. In his view, this approach failed to consider cultural differences and unfairly disadvantaged claimants who could not meet these stringent requirements through no fault of their own.