In the United States v. Anderson case of 1903, the Supreme Court ruled on a dispute involving land ownership in California. The defendant, Anderson, claimed that he had purchased land from an individual who received it as part of a Mexican Land Grant before California became part of the U.S., and thus his title was valid under the Treaty of Guadalupe Hidalgo. However, this claim was disputed by another party who argued that they held rightful ownership due to purchasing it directly from the state after it joined America. The court decided in favor of Anderson's argument because according to Article VIII of said treaty between Mexico and US (1848), property rights were protected for those living in territories ceded to America regardless if their titles were formally recognized or not at time when territory changed hands.

In the dissenting opinion for United States v. Anderson, Justice Harlan argued that the majority's decision was a misinterpretation of the law and could potentially lead to unjust outcomes. He contended that under their interpretation, any person who had been in possession of public lands for a significant period without being challenged by the government would be able to claim ownership over those lands. This, he believed, would encourage unlawful occupation and exploitation of public property. Furthermore, he disagreed with the majority's view that Congress intended to grant such rights through its legislation on this matter. Instead, he asserted that these laws were designed to protect settlers from eviction while they established their homes and farms but not meant as an open invitation for anyone to seize control over unclaimed land indefinitely.