In the United States v. Texas case of 1891, the Supreme Court was asked to resolve a dispute over territory between the U.S. federal government and the state of Texas. The controversy arose from an area known as Greer County, which both parties claimed ownership over due to differing interpretations of an 1819 treaty with Spain that defined boundaries for Louisiana Purchase territories. The court ruled in favor of the United States, determining that according to their interpretation of this treaty's language, Greer County fell within U.S.-controlled land rather than being part of Texas' jurisdiction as it had previously been administered since its annexation by Congress in 1845. This decision effectively expanded Oklahoma Territory at Texas’ expense.

In the dissenting opinion for United States v. Texas, 1891, Justice Lamar disagreed with the majority's decision that the federal government had jurisdiction over a dispute about land in Texas. He argued that when Texas joined the Union, it retained control over its public lands and did not cede this power to Congress. Therefore, he believed that any disputes regarding these lands should be resolved by state courts rather than federal ones. Furthermore, he contended that even if Congress did have some authority over these lands due to their connection to Native American tribes or other national interests, this case was purely a matter of state law because it involved a private land claim against the state of Texas itself.