In the United States v. Mesa case of 1912, the Supreme Court ruled on a dispute involving land rights in New Mexico. The defendant, Mr. Mesa, claimed ownership of certain lands under a Spanish grant that was confirmed by Congress but had not been surveyed or patented at the time he sold them to another party. The government argued that until such survey and patent were issued, no title passed from it to any private person; hence Mr. Mesa could not have transferred what he did not own himself. The court held that while confirmation by Congress gave an equitable title (a claim recognized by a court of equity), it did not give legal title (official ownership). Therefore, even though Mr. Mesa's sale might be valid in equity against him and those claiming under him with notice of this fact - meaning they knew about his lack of full legal rights - it would still be void as against the United States or anyone who purchased from them without such notice. This decision clarified how property laws applied when dealing with land grants made before territories became part of the U.S., emphasizing both their complexity and potential for conflict between different systems.

In the dissenting opinion for United States v. Mesa, the justice argued that there was insufficient evidence to support a conviction of conspiracy to defraud the government. The defendant, Mesa, had been accused of conspirifying with others to submit false claims for payment from federal funds allocated for Indian education. However, according to this dissenting view, no concrete proof was provided demonstrating that Mesa knowingly participated in such fraudulent activity or intended any harm towards the government's interests. Furthermore, it was contended that mere knowledge of wrongdoing by others does not necessarily imply participation or agreement in said wrongdoing; thus making guilt by association unjustifiable without further substantiating evidence. This perspective emphasized strict adherence to legal standards and principles over circumstantial implications when determining an individual's culpability.