In Spalding v. Castro (1893), the United States Supreme Court ruled on a dispute involving land rights in California, which had been granted by Mexico prior to its cession to the U.S. The plaintiff, Spalding, claimed ownership of a tract of land based on an alleged Mexican grant made before 1848 when California was acquired by the U.S., while defendant Castro asserted his title under a patent issued by the United States in 1871. The court held that evidence supporting Spalding's claim was insufficient and unreliable as it relied heavily on testimonies from witnesses who were either interested parties or whose credibility could not be established beyond doubt. Furthermore, there were discrepancies between different translations of documents presented as evidence for this claim. Therefore, it upheld Castro’s title under the patent issued by the U.S government.

The dissenting opinion in the Spalding v. Castro case argued that the majority's decision was incorrect because it failed to properly consider California law, which should have governed this dispute over land ownership. The dissent emphasized that under California law, a grant of land is presumed valid until proven otherwise and noted that there was no evidence presented at trial to suggest fraud or mistake in the original grant of land to Castro. Furthermore, they pointed out inconsistencies between federal and state laws regarding property rights and suggested these discrepancies were not adequately addressed by the majority opinion. They also criticized how certain pieces of evidence were interpreted by their colleagues on the bench, arguing for a different interpretation more favorable to Mr. Castro’s claim.