In the 1909 case of Reavis v. Fianza, the United States Supreme Court addressed a dispute over land ownership in New Mexico. The plaintiff, Reavis, claimed that he had purchased a Spanish land grant from an individual named Peralta-Reavis and sought to evict defendant Fianza from this property. However, it was determined that there were significant issues with the authenticity of Peralta-Reavis's claim to the land grant; investigations revealed numerous forgeries and falsifications in his documents supporting his alleged ownership. Consequently, it was ruled that Reavis did not have valid title to the disputed property because his purchase was based on fraudulent documentation provided by Peralta-Reavis. Therefore, he could not legally evict Fianza who held legitimate rights over said property under U.S law at that time.

The dissenting opinion in the case of Reavis v. Fianza argued that the majority's decision to uphold a lower court ruling, which found Mr. Reavis guilty of fraud and ordered him to pay restitution, was incorrect. The dissenting justices believed that there were significant issues with how evidence was handled during the trial and felt that these procedural errors should have resulted in a reversal of Mr. Reavis' conviction rather than an affirmation by the Supreme Court. They also expressed concern about potential bias on behalf of some members of the jury who may have had personal or financial ties to parties involved in this case, arguing it could compromise their impartiality as jurors.