In the 1904 U.S. Supreme Court case Sixto v. Sarria, the court examined a dispute over property rights in Florida that originated from Spanish land grants predating American ownership of the territory. The plaintiff, Sixto, claimed ownership based on an alleged grant by Spain to his ancestors before Florida was ceded to the United States in 1821. However, he failed to provide sufficient evidence supporting this claim and could not prove continuous possession or cultivation of said lands since then. The defendant, Sarria had purchased part of these lands through tax sales conducted by state authorities due to non-payment of taxes by previous owners who were recognized as such under US law after Florida's acquisition. The Supreme Court ruled in favor of Sarria stating that even if there had been a valid original grant (which was not proven), failure to pay taxes leading to legal tax sales would have extinguished any prior claims. Furthermore, it held that long-term adverse possession without challenge also conferred legitimate title under common law principles. This decision reinforced two key aspects: firstly - importance and legitimacy of public records for determining property rights; secondly - necessity for active maintenance and defense against encroachments for preserving one's property interests.

The dissenting opinion in the case of Sixto v. Sarria, 1904, argued that the majority's decision was incorrect because it failed to properly consider Spanish law and its application at the time of Cuba's cession to the United States. The dissenting justices believed that under Spanish law, a mortgage could be extinguished by non-use for twenty years only if there were no legal impediments preventing foreclosure during this period. They pointed out that due to various wars and political instability in Cuba over these two decades, such legal impediments did exist which prevented foreclosure action from being taken on Sixto’s property. Therefore, they concluded that Sarria’s claim should not have been dismissed as his right to foreclose had not expired according to their interpretation of relevant laws.