In the 1916 case Alder v. Edenborn, the United States Supreme Court dealt with a dispute over mining rights in Colorado. The plaintiff, Alder, claimed that he had purchased land from an individual who had previously obtained it through a patent issued by the U.S government under its Mining Act of 1872. However, defendant Edenborn argued that this patent was invalid because it did not meet certain requirements set out in the act - specifically that valuable mineral deposits were discovered on the land before its acquisition and extraction activities were ongoing at time of purchase. The lower court ruled in favor of Edenborn but upon appeal to Supreme Court, justices reversed this decision stating there was no requirement for continuous operation or production after discovery under said law; hence making original patent valid and affirming Alder's ownership claim.

In the dissenting opinion for Alder v. Edenborn, it was argued that the majority's decision to uphold a lower court ruling which allowed a corporation to issue bonds and preferred stock in exchange for property rights violated principles of corporate law. The dissenting justices believed this transaction unfairly diluted the value of existing common shares without providing adequate compensation or obtaining shareholder approval. They contended that such actions were not within the powers granted to corporations under state law and should be considered illegal unless explicitly authorized by shareholders. Furthermore, they expressed concern about potential abuses if corporations could arbitrarily reduce share values through similar transactions without any checks or balances from shareholders or courts.