In the case of United States v. Storrs et al., 1926, the US Supreme Court dealt with a dispute over land ownership in New Mexico. The defendants claimed that they had acquired title to certain lands through Spanish and Mexican grants prior to the Treaty of Guadalupe Hidalgo in 1848, which ended the Mexican-American War and ceded large portions of Mexico's northern territories to the United States. However, these claims were rejected by both lower courts and eventually by Supreme Court as well due to lack of sufficient evidence proving their validity. The court ruled that under Article VIII of this treaty, only those titles recognized by Spain or Mexico before its signing would be upheld by U.S law; any other claims must go through Congress for validation rather than being decided upon judicially. Therefore, since there was no proof showing recognition from either country regarding these specific lands before 1848 nor any congressional action validating them afterwards, it was concluded that they remained public domain owned by U.S government.

The dissenting opinion in the United States v. Storrs case argued that the government had not provided sufficient evidence to prove that the defendants were guilty of conspiracy to defraud. The dissenting justices believed that while there was evidence of wrongdoing on behalf of some individuals, it did not necessarily implicate all those charged in the conspiracy. They also took issue with how broadly the term "conspiracy" was being applied in this case, arguing it could potentially criminalize innocent actions if interpreted too loosely. Furthermore, they disagreed with majority's interpretation and application of law regarding fraudulent intent and its requirement for conviction under charges brought against defendants.