In Springer Land Association v. Ford (1897), the U.S. Supreme Court was asked to determine whether a land grant made by Mexico before it ceded territory to the United States under the Treaty of Guadalupe Hidalgo remained valid. The case involved a dispute over 11 square leagues of land in California, which had been granted by Mexican authorities to two citizens shortly before the treaty was signed in 1848. After acquiring this property, Springer Land Association faced opposition from another party claiming ownership based on an older Spanish grant that allegedly encompassed part of these lands. The court ruled against Springer Land Association, holding that its claim did not meet certain requirements set out in U.S law for confirming such grants made under previous sovereigns - specifically, they failed to provide sufficient evidence proving continuous possession and use since obtaining their title from Mexico's governor back then. This decision underscored how American courts would interpret and apply principles related with international law and treaties when dealing with issues concerning real estate titles originating from foreign jurisdictions prior their incorporation into U.S territory.

In the dissenting opinion for Springer Land Association v. Ford, Justice Harlan argued that the court majority had erred in its interpretation of the law and constitutionality surrounding land grants. He contended that Congress did not intend to grant lands to railroad companies without conditions or restrictions, as suggested by the majority's ruling. Instead, he believed these grants were made with clear stipulations regarding their use and disposal - primarily for building railroads and related infrastructure. Furthermore, he disagreed with the majority's view on 'in lieu' lands (lands given in replacement of those initially granted but found unsuitable), arguing they should be treated under similar restrictions as original grant lands rather than being freely disposable property of railroad companies. In essence, Justice Harlan held a more restrictive view on how land grants should be interpreted and applied compared to his peers in this case.