In the United States v. McMullen et al., Administrators case of 1911, the Supreme Court ruled on a dispute over land ownership in California. The U.S government claimed that it had never legally transferred ownership of certain lands to private parties, despite those parties having lived and worked there for many years under assumed titles. The defendants were administrators of estates who believed they held rightful claim to these lands based on Spanish and Mexican land grants predating California's statehood, which they argued should be honored by the U.S following its acquisition of California from Mexico in 1848. However, the court found no evidence that such grants existed or were validly made according to then-existing laws; thus ruling against them. Furthermore, even if such grants did exist but weren't presented within two years after acquiring possession as required by an Act passed in March 3rd 1851 (confirming invalidity), their claims would still fail because this period had long expired before this litigation began.

In the dissenting opinion for United States v. McMullen et al., Administrators, Justice Holmes disagreed with the majority's decision to deny recovery of funds from a deceased postmaster’s estate who had embezzled money while in office. He argued that the government should be able to recover these stolen funds as they were property of the U.S. Treasury at all times and never legally belonged to the postmaster or his estate. The fact that he was dead did not change this principle, nor did it absolve his administrators from their duty to return misappropriated public monies back into federal coffers. Furthermore, Holmes contended that there was no legal basis for distinguishing between an executor being held liable for debts incurred by fraud and one being held accountable for stolen money still within an estate’s possession.