In the 1892 case of San Pedro and Canon Del Agua Company v. United States, the Supreme Court ruled in favor of the U.S. government regarding a land dispute in New Mexico. The San Pedro and Canon Del Agua Company claimed ownership over certain lands based on an old Spanish grant made before Mexico ceded territory to the U.S., but failed to present their claim within two years as required by Congress's Act of July 22, 1854. The company argued that this time limit was unconstitutional because it deprived them of property without due process; however, they had not taken any action for nearly thirty years after learning about this requirement. Therefore, the court held that there was no violation of due process rights since ample opportunity had been given for presenting claims under Mexican grants following territorial acquisition by treaty from Mexico.

The dissenting opinion in the case of San Pedro and Canon Del Agua Company v. United States argued that the majority's decision to uphold a lower court ruling, which found in favor of the U.S. government, was incorrect. The dissenters believed that there were significant errors made during trial proceedings and these mistakes had influenced the outcome unfairly against San Pedro and Canon Del Agua Company. They contended that certain evidence presented by the company should have been admitted but was erroneously excluded by the trial judge, thus denying them a fair hearing. Furthermore, they disagreed with how property rights were interpreted under Spanish law - an important aspect given New Mexico's history as a former Spanish colony - arguing it favored unjustly towards U.S government’s claim on land grants.