John Catron,
Marsh v. Brooks (55 U.S. 513)…
“ That a complete title to the land in controversy was vested in Thomas F. Reddick, on the 29th of April, 1816, whether the 'Indian rights' had, or had not, then been extinguished; and the title so vested has not been divested or impaired, by any subsequent treaty or act of Congress.A confirmation of a title by act of Congress, not only renders it a legal title, but furnishes higher evidence of that fact than a patent, inasmuch as it is a direct grant of the fee by the government itself, whereas a patent is only an act of its ministerial officer. ”
