In the 1898 case of Nugent v. Arizona Improvement Company, the United States Supreme Court dealt with a dispute over land ownership in Arizona. The plaintiff, Nugent, claimed that he had acquired title to certain lands through purchase from an individual who had received a patent for them from the U.S government under mining laws. However, the defendant company argued that they held valid title to these lands due to their acquisition of Mexican land grants which predated any American claims and were recognized by treaty upon annexation of territory after Mexican-American War. The court ruled in favor of Nugent stating that his claim was superior because it originated from federal law while recognizing validity of Mexican land grants only when confirmed by Congress or courts as per Treaty obligations but not automatically self-executing against subsequent good faith purchasers under US patents.

The dissenting opinion in the case of Nugent v. Arizona Improvement Company argued that the majority's decision was flawed because it failed to consider important aspects of property law and equity. The dissenting justices believed that Nugent had a valid claim to the land, as he had made significant improvements on it with his own labor and resources, demonstrating an intent to possess and use the land for productive purposes. They contended that this should have been enough to establish a right of possession under common law principles, regardless of any technical defects in his title. Furthermore, they disagreed with the majority's interpretation of federal mining laws, arguing instead that these laws were intended not just to promote mineral discovery but also encourage settlement and development by granting rights based on actual occupancy and improvement rather than mere formal title claims. Therefore, they concluded that denying Nugent’s claim would undermine these broader policy goals while unjustly enriching speculators who contributed nothing towards improving or developing lands.