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Botiller v. Dominguez

130 U.S. 238 (1889)

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Botiller v. Dominguez

United States Supreme Court

130 U.S. 238 (1889)

Facts

At the end of the war with Mexico, the United States gained land formerly owned by Mexico through a peace treaty, the Treaty of Guadalupe Hidalgo. The land that comprises California was transferred under this treaty, which also sought to protect the property owned by Mexican citizens prior to the treaty. Subsequently, the Act of Congress of March 3, 1851, established the California Land Claims Commission to determine the validity of private land claims in the state, including the claims of Mexican citizens whose lands had been granted by the Mexican government before the peace treaty. More than 40 years after the Land Claims Commission was established, some private landowners had still not presented their claims to the commission to have their ownership confirmed. Dominga Dominguez (defendant) was a private landowner who claimed that title to his land, Rancho Las Virgenes, was granted to him by the Mexican government. Dominguez attempted to eject another, Brigido Botiller (plaintiff), from his land; however, he had never submitted his claim to the commission to establish his ownership. The California Supreme Court decided that the act that created the commission was invalid. It reasoned that the California Land Claims Commission had no jurisdiction to determine the validity of titles to private land that had been established by the government of Mexico prior to the land being transferred to the United States. The United States Supreme Court considered the validity of the lower court’s decision.

Rule of Law

Issue

Holding and Reasoning (Miller, J.)

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