In the case of The Dos Hermanos, Shields, Claimant (1825), the Supreme Court was asked to decide whether a Spanish grant from 1795 could be recognized in an American court. At issue was whether or not Spain had validly granted land to two brothers who were citizens of Mexico at that time. After considering evidence presented by both sides and examining relevant laws and treaties between Spain and America, the Supreme Court ruled that although there may have been some irregularities in how the grant was made, it should still be respected as valid under international law. Furthermore, they held that since Mexico had become independent from Spain before this dispute arose, any rights acquired through Spanish grants would now fall under Mexican law instead. This ruling established precedent for recognizing foreign titles within U.S courts when appropriate circumstances are present.

In The Dos Hermanos case, the Supreme Court ruled in favor of Shields, the claimant. However, Justice Story dissented from this opinion and argued that there was no evidence to support a finding of title in Shields' favor. He noted that while it is true that possession alone does not constitute ownership or title to land, it can be used as evidence when combined with other facts such as long-term occupancy and improvements made by an individual on the property. In this case however, he found no such proof presented by Shields which would have been necessary for him to establish his claim over the disputed land. Therefore Justice Story concluded that without any additional supporting evidence beyond mere possession of the property at issue here, Shield's claim should fail and judgment should be entered against him instead.