In the case of Morgan v. Potter, 1894, the United States Supreme Court ruled on a dispute involving land ownership in California. The plaintiff, Morgan, claimed that he had purchased a tract of land from an individual who had received it as part of a Mexican Land Grant before California became part of the U.S., and thus his claim was valid under the Treaty of Guadalupe Hidalgo. However, defendant Potter argued that this grant was invalid because it hadn't been confirmed by Congress or patented by any President as required by law for all such grants after 1851. The court sided with Potter stating that while treaty rights were important to uphold; they did not supersede existing laws requiring congressional confirmation and presidential patenting for validity of land grants made post-1851 even if those lands were originally granted prior to American acquisition.

In the dissenting opinion for Morgan v. Potter, Justice Brewer argued that the majority's decision to uphold a tax on distilled spirits was incorrect because it violated principles of double taxation. He contended that once a tax had been levied and paid on a particular item, in this case distilled spirits, any further taxes constituted an unlawful form of double taxation. In his view, the government should not be able to impose multiple taxes on the same property or transaction without explicit authorization from Congress. Furthermore, he disagreed with the majority's interpretation of relevant statutes and believed they did not provide clear authority for such additional taxation. Thus, Justice Brewer concluded that upholding these additional taxes was both legally unjustifiable and contrary to fundamental principles of fairness in taxation.