United States v. Bell & Another is a United States Supreme Court case that was decided in 1884. The case involved a dispute between the United States and two individuals, Bell and another, over the ownership of a parcel of land in the state of California. The United States argued that the land had been granted to them by the Mexican government prior to the Mexican-American War, and that the two individuals had no right to the land. The two individuals argued that they had acquired the land through a valid grant from the Mexican government. The Supreme Court ultimately sided with the United States, ruling that the land had been granted to the United States prior to the Mexican-American War and that the two individuals had no valid claim to the land. The Court held that the Mexican government had no authority to grant the land to the two individuals, as the land had already been granted to the United States. The Court also held that the two individuals had no right to the land, as they had not acquired it through a valid grant from the Mexican government. As a result, the Court ruled in favor of the United States and held that the land belonged to the United States.

Justice Field delivered the dissenting opinion in United States v. Bell & Another, arguing that the majority's decision was inconsistent with prior Supreme Court precedent and would lead to a dangerous expansion of federal power. He argued that Congress had no authority under either the Constitution or any act of Congress to pass laws governing private contracts between individuals, as this case involved. Furthermore, he asserted that such an interpretation would allow for unlimited interference by Congress into matters traditionally left to state governments and courts. In addition, Justice Field noted that if the majority's ruling were allowed to stand it could be used as justification for future expansions of congressional power beyond what is authorized by law or even contemplated by its framers at the time of adoption. Finally, Justice Field concluded his dissent stating "I cannot assent to so broad a construction [of Congressional powers] without doing violence both to my own convictions and those which I find expressed in many decisions heretofore made."