23 март 1868 г. - Supreme Court decides Grisar v. McDowell, concerning disposition of public lands in the past by President Fillmore. The ruling underscores presidential unilateral powers. The Court concluded “from an early period in the history of the government it has been the practice of the President to order, from time to time, as the exigencies of the public service required, parcels of land belonging to the United States to be reserved from sale and set apart for public uses.”