In the case of Putnam v. United States (1895), the U.S Supreme Court ruled on a dispute involving land grants in Florida. The plaintiff, George P. Putnam, claimed that he had purchased lands from the state of Florida which were part of a grant made by Congress to aid in constructing railroads. However, these lands were also claimed by other parties who had received them directly from Congress under another act for swamp and overflowed lands reclamation purposes. The court held that when there is conflict between two federal statutes granting public lands to states for different purposes, priority should be given according to the order they are passed unless it can be shown that later statute was intended to supersede or modify earlier one. In this case, since both acts did not express any intention regarding their relationship with each other and because railroad grant was older than swamp-land grant; therefore its rights prevailed over latter's claims even though it hadn't been identified or listed at time when swamp-land act was passed. Thus ruling favored Mr.Putnam but also clarified legal position about conflicting land-grants which would guide future such disputes.

In the dissenting opinion for Putnam v. United States, Justice Brewer argued that the government had no right to seize property from a private citizen without providing just compensation. He believed that this case was not about whether or not Mr. Putnam owed taxes, but rather if his rights as a property owner were violated by the seizure of his land and its subsequent sale by the government. According to Justice Brewer, even though Mr. Putnam did owe back taxes, he should have been given an opportunity to pay them before any action was taken against him; instead, he was denied due process when his land was seized and sold without notice or hearing in direct violation of constitutional protections under Fifth Amendment's Takings Clause.