In the case of Sawyer v. Gray, 1914, the United States Supreme Court dealt with a dispute over land ownership in California. The plaintiff, Sawyer, claimed that he had acquired title to certain lands through preemption rights under federal law and sought to eject defendant Gray from these lands. However, the defendant argued that they held valid title due to a Mexican grant which was confirmed by an act of Congress in 1866 and patented by President Lincoln's successor Andrew Johnson. The court ruled in favor of Gray stating that once Congress confirms such grants and patents are issued thereon; it is not within their power or jurisdiction to question its validity or inquire into circumstances surrounding its issuance unless fraud can be proven on part of government officials involved in granting patent itself - something which was not alleged nor proven here.

In the dissenting opinion for Sawyer v. Gray, it was argued that the majority's decision to uphold a law prohibiting non-residents from fishing in Washington state waters violated the Privileges and Immunities Clause of Article IV of the U.S. Constitution. The dissenting justices believed that this clause should protect citizens' right to earn a livelihood across state lines, including through commercial fishing activities. They contended that while states have power over their natural resources, they cannot discriminate against out-of-state residents when granting access to these resources for business purposes without violating constitutional principles of equality among citizens from different states.