The Western Tie and Timber Company v. Brown case in 1904 revolved around a dispute over land ownership. The plaintiff, Western Tie and Timber Company, claimed that they had purchased the disputed property from an individual who had received it through a patent issued by the United States government under the Swamp Land Act of 1850. However, defendant Brown argued that he held rightful claim to this land because he was given possession of it as part of an Indian allotment approved by Congress in 1891. The Supreme Court ruled in favor of Brown, stating that once Congress approves an Indian allotment, all previous claims on said lands are nullified regardless if they were granted patents or not prior to the approval date. This ruling reaffirmed tribal sovereignty rights and established precedent for future cases involving disputes between private entities and Native American tribes over land ownership.

In the dissenting opinion for Western Tie and Timber Company v. Brown, it was argued that the majority's decision failed to properly consider the nature of property rights in relation to land patents. The dissent emphasized that a patent for land is not merely an assertion of title by the government but also serves as evidence of its relinquishment of any claim to said land. Therefore, if there are errors or fraud involved in obtaining such a patent, it should be voided only through direct proceedings initiated by the government itself rather than private individuals or corporations. This perspective maintains that allowing private parties to challenge these patents undermines their purpose and could lead to instability in property law due to potential constant litigation over titles granted long ago.