In the United States v. United Engineering and Contracting Company case of 1913, the Supreme Court ruled on a dispute involving land ownership in New Mexico. The U.S government claimed that certain lands were public domain while the defendant company argued they had acquired valid title to these lands through Mexican grants prior to American acquisition of New Mexico. The court held that under international law, rights and titles established by one nation must be respected by any succeeding sovereign power unless explicitly annulled or modified. Therefore, if a valid grant was made under Mexican rule before American acquisition, it would still hold legal weight unless specifically invalidated by Congress after annexation. However, in this particular case, there was insufficient evidence proving such grants existed or were legally recognized at the time of transfer from Mexico to America; hence no private property rights could have been violated when these lands were declared part of public domain.

In the dissenting opinion for United States v. United Engineering and Contracting Company, Justice Holmes disagreed with the majority's decision to hold the defendant company liable for damages caused by a flood that resulted from its construction of a dam on behalf of the U.S. government. He argued that there was no evidence showing negligence or misconduct on part of the company in constructing or maintaining this dam which led to flooding downstream damaging private property owners' land. According to him, if any liability existed it should be borne by government as they were aware about potential risks associated with such projects but still chose to proceed due their necessity for public welfare purposes like irrigation and power generation etc., thus making them responsible under doctrine of eminent domain where state can take private property for public use but has to provide just compensation in return.