In the United States v. Alexander case of 1892, the Supreme Court ruled on a dispute involving land ownership in California. The defendant, Alexander, claimed that he had purchased a parcel of land from an individual who had obtained it through preemption rights under federal law. However, the U.S government argued that this was not possible as there were no records to support such claim and thus considered it public property. The court held that while preemption laws did allow for individuals to acquire public lands before they were officially surveyed by purchasing them at minimum price set by Congress; proof of these transactions must be provided via official record or other substantial evidence which was lacking in this case. Therefore, the Supreme Court sided with the government ruling that without proper documentation proving otherwise, all unsurveyed lands are presumed to belong to the U.S Government until proven otherwise.

In the dissenting opinion for United States v. Alexander, Justice Brewer argued that the court majority erred in its interpretation of the law and constitution. He contended that Congress did not have authority to regulate commerce within a state's boundaries unless it directly impacted interstate or foreign trade. In this case, he believed there was no evidence showing such impact from Alexander’s actions on his own property within Washington State. Furthermore, he asserted that if every action with potential indirect effects on interstate commerce were subject to federal regulation, then virtually all private activities could be federally controlled - an outcome contrary to principles of limited government and states’ rights enshrined in the Constitution.