In the case of United States v. Soldana et al., 1917, the Supreme Court dealt with a dispute over land ownership in California. The defendants, Soldana and others, claimed that they had acquired title to certain lands through Mexican grants before California became part of the U.S. However, these claims were not presented for confirmation under an act passed by Congress in 1851 which required all persons claiming titles to lands in California based on Spanish or Mexican grants to present their claims within two years from the date of passage of this act. The court ruled against Soldana and his co-defendants stating that failure to present their claim within this period resulted in forfeiture of any rights they might have had under such grant. This decision upheld Congressional power over property disputes arising from territories gained after war.

The dissenting opinion in the United States v. Soldana case argued that the majority's decision to uphold a conviction for conspiracy to defraud was flawed because it relied on an overly broad interpretation of what constituted "fraud." The dissenters contended that not all dishonest or deceptive acts should be considered fraudulent under federal law, especially when they do not result in tangible harm or loss. They also expressed concern about potential overreach and abuse of power by prosecutors who could use this expansive definition of fraud to target individuals for minor infractions or conduct that would otherwise be legal. Furthermore, they disagreed with the majority's assertion that intent alone is sufficient grounds for prosecution, arguing instead that there must be evidence of actual harm caused by the alleged fraudulent activity.