In the United States v. King case of 1892, the Supreme Court ruled on a dispute over land ownership in California. The plaintiff, the U.S., contested that certain lands claimed by defendant King were actually public lands and not part of any Mexican or Spanish land grant recognized under the Treaty of Guadalupe Hidalgo following the Mexican-American War. The court held that while there was evidence suggesting some form of grant may have been made to an individual named Castro (from whom King claimed title), it was insufficient to establish a valid claim due to lack of proper documentation and confirmation procedures required by law at that time for such grants. Therefore, these lands were deemed as public domain belonging to U.S government rather than private property owned by Mr.King.

The dissenting opinion in the United States v. King case, delivered by Justice Brewer, argued that the court majority had erred in its interpretation of the law and overstepped its jurisdiction. He contended that it was not within their power to decide whether or not a claim should be allowed against an Indian tribe unless Congress specifically gave them such authority. According to him, this decision violated principles of sovereignty as tribes were independent political communities with inherent rights and powers which could only be altered or abolished by Congress. Furthermore, he disagreed with the majority's view on treaty interpretation stating that treaties should always be interpreted favorably towards Indians given their disadvantaged position during negotiations.