The U.S. Supreme Court case Russell v. Maxwell Land Grant Company in 1894 revolved around a dispute over land ownership rights between the Maxwell Land Grant Company and settlers who had been living on the property for years, including William H. Russell. The company claimed that it owned all of the land under an old Mexican grant, while Russell argued that he and other settlers had acquired their own valid titles to parts of the property through preemption laws (laws allowing individuals to settle on public lands). The court ruled in favor of the Maxwell Land Grant Company, stating that its title was superior because it originated from a treaty with Mexico following the Mexican-American War which recognized existing grants made by Spain or Mexico before American acquisition. This decision upheld large-scale private ownership claims against those of individual settlers.

The dissenting opinion in the case of Russell v. Maxwell Land Grant Company argued that the majority's decision was incorrect because it failed to properly consider and apply established legal principles related to land grants. The dissent contended that under Spanish law, which governed at the time of the grant, a valid title could be created without any formal act of possession by the grantee or any official delivery by government authorities. It also disagreed with how evidence was interpreted regarding whether there had been sufficient acts demonstrating intent to take possession of granted lands. Furthermore, it criticized how certain documents were dismissed as not being authentic or reliable enough for consideration in proving ownership claims. Finally, it expressed concern over potential negative impacts on property rights and security if such strict standards for proof were applied universally.