In the case of A. C. Frost & Co. v. Coeur D'Alene Mines Corp., 1940, the U.S Supreme Court ruled in favor of Coeur D’Alene Mines Corporation, reversing a previous decision by lower courts that had favored A.C Frost & Company. The dispute arose over mining properties in Idaho where both companies claimed ownership rights to certain veins or lodes of ore beneath the surface land owned by A.C Frost & Company but leased to Coeur D’Alene Mines Corporation for mining purposes under an agreement dating back to 1921.The court held that according to federal law and local customs, subsurface mineral rights belong to whoever first locates them and complies with statutory requirements for perfecting their claim - regardless of who owns the surface land above it.

In the dissenting opinion for A. C. Frost & Co. v. Coeur D'Alene Mines Corp., Justice Black disagreed with the majority's decision to uphold a lower court ruling that denied recovery of stock shares on grounds of fraud, due to an alleged failure by plaintiffs to prove they had relied upon false representations made by defendants in purchasing said stocks. He argued that this interpretation was too narrow and did not adequately consider established legal principles regarding fraudulent misrepresentation and deceit, which do not always require proof of reliance as a prerequisite for recovery in cases where material facts were concealed or misrepresented intentionally or recklessly by one party causing injury to another party who acted upon such concealment or misrepresentation unknowingly.