In the Moore v. United States case of 1895, the Supreme Court ruled on a dispute over land in California that had been granted to John A. Sutter by Mexico before it ceded California to the U.S. The issue was whether this grant was valid under U.S law after California became part of America following the Mexican-American War and subsequent Treaty of Guadalupe Hidalgo. The court held that even though there were irregularities with how Sutter obtained his title from Mexico, these did not invalidate his claim because he had fulfilled all necessary conditions imposed by Mexican law at that time for obtaining ownership rights over public lands. Therefore, according to principles established in previous cases about property rights retained after territory changes sovereignty (like those involving Louisiana Purchase), such grants are recognized as valid under American law if they were legitimate under laws of former sovereign when made.

In the dissenting opinion for Moore v. United States, Justice Brewer argued that the majority's decision to uphold a conviction based on evidence obtained through an illegal search and seizure was fundamentally flawed. He contended that such actions violated the Fourth Amendment rights of citizens, which protect against unreasonable searches and seizures. Furthermore, he maintained that allowing illegally obtained evidence to be used in court would incentivize law enforcement officers to disregard constitutional protections in their pursuit of convictions. In his view, upholding this conviction undermined not only individual liberties but also public trust in the justice system as it essentially sanctioned unlawful conduct by those sworn to uphold the law.