In the United States Supreme Court case of The United States v. Samuel Davenport's Heirs, the court was asked to decide whether a patent issued by Congress in 1802 for land located in Mississippi Territory was valid or not. At issue were two conflicting claims: one from Samuel Davenport and his heirs, who claimed that they had purchased the land prior to 1802; and another from William Lattimore, who argued that he had obtained a valid grant for it under an act of Congress passed in 1798. After examining both sides' arguments, the court determined that while Lattimore did have a valid claim based on his congressional grant, it could not supersede Davenport's earlier purchase of the property. Therefore, Davenport’s heirs were found to be rightful owners of this disputed piece of land.

In the United States v. Samuel Davenport's Heirs, the Supreme Court was asked to decide whether a federal statute that authorized the sale of public lands for nonpayment of taxes applied retroactively to land owned by Samuel Davenport prior to its enactment. The majority opinion held that it did not and thus could not be used as a basis for selling his land after his death without first obtaining an act from Congress authorizing such action. Justice McLean dissented on this point, arguing that since there was no express prohibition against applying the statute retroactively in this case, it should be allowed to do so. He argued further that if Congress had intended otherwise they would have made their intention clear in either the language or legislative history of the law itself. In conclusion he stated “I am unable to perceive any good reason why [the] act should not operate upon all cases where delinquencies existed at its passage” and therefore concluded that it should apply here as well