In the case of United States v. Title Insurance & Trust Company et al., 1923, the U.S Supreme Court ruled in favor of the federal government's right to reclaim public lands that had been fraudulently obtained by private entities. The court held that a statute of limitations did not apply to suits brought by the United States as a sovereign power seeking to assert its rights or protect its interests. This decision was based on an investigation into Southern California land grants which revealed widespread fraud and corruption involving millions of acres granted under Spanish and Mexican land laws prior to California statehood. The ruling allowed for recovery actions against corporations and individuals who had acquired these lands unlawfully, reinforcing governmental authority over public domain management.

In the dissenting opinion for United States v. Title Insurance & Trust Company, Justice McReynolds disagreed with the majority's interpretation of the Act of 1851 and its application to this case. He argued that there was no evidence showing Congress intended to grant land in California to anyone other than those who could prove they had received a valid Mexican or Spanish grant before 1848. The justice believed that any claim based on an alleged possession after 1848 should not be recognized by U.S courts as it would contradict both international law and treaty obligations between Mexico and America at that time. Furthermore, he contended that if such claims were allowed, it would open up countless opportunities for fraudulent activities which could harm genuine landowners' rights. Therefore, he concluded that the Court erred in affirming judgment against defendants without requiring proof from plaintiffs about their legal title under Mexican laws prior to American occupation.