In The United States v. The Heirs of George J.F. Clarke and the Heirs of George Atkinson, the Supreme Court was asked to decide whether a patent issued by Congress for land in Missouri was valid or not. At issue were two conflicting claims: one from an individual who had purchased the land from its original owner before it became part of the United States, and another from a group that claimed they had inherited title to it through their ancestor's will after it became part of the US. After considering both sides' arguments, as well as relevant statutes and case law, the court determined that since there was no evidence that either party held legal title prior to when Missouri became a state in 1821, neither could claim ownership rights over this particular piece of property under federal law at that time; thus making any patents issued by Congress invalid on this matter.

The dissenting opinion in this case argued that the United States had no right to bring a suit against the heirs of George J.F. Clarke and George Atkinson, as they were not parties to any contract between the US government and their ancestors who owned land in what is now Alabama prior to 1814. The dissent argued that these individuals could only be held liable if they had personally entered into an agreement with the US government or assumed responsibility for such an agreement through some other means, which was not present here. Furthermore, it was asserted that even if there were grounds for holding them responsible under existing law, those laws did not apply retroactively so far back as 1814 when their ancestors originally acquired title to the property at issue in this case. As such, it was concluded that there existed no legal basis upon which liability could be imposed on these appellees by way of a lawsuit brought by the United States government against them directly rather than against their predecessors-in-title from whom they inherited said property rights many years later.