In the case of Andrew G. Nelson, Inc., v. United States et al., 1957, the Supreme Court ruled on a dispute over land ownership in California between private parties and the federal government. The issue at hand was whether or not a patent issued by the U.S Government to Andrew G. Nelson, Inc for certain lands in California included oil and gas rights beneath those lands or if they were reserved by an Act of Congress passed before issuance of that patent. The court held that under Section 1 of an Act passed on February 25th, 1920 (known as Mineral Leasing Act), all oil and gas deposits within any part of public land were retained by Federal Government even after transferring surface rights to private entities through patents unless explicitly mentioned otherwise in such patents. Therefore, it concluded that since there was no explicit mention about transferal of mineral rights including oil & gas reserves along with surface rights in this particular case; these remained with US Government despite issuing patent for surface land to Andrew G. Nelson Inc.

In the dissenting opinion for Andrew G. Nelson, Inc., v. United States et al., Justice Brennan argued that the majority's decision to uphold a tax on imported goods was misguided and inconsistent with previous court rulings. He contended that the tax in question did not fall under Congress' power to regulate commerce but instead constituted an impermissible duty on imports, which is expressly prohibited by Article I of the Constitution. Furthermore, he disagreed with the majority's interpretation of what constitutes a "duty," arguing that any charge imposed on imports should be considered as such regardless of its purpose or how it is used by government authorities. In his view, this broad interpretation would better align with both constitutional text and historical precedent while also preventing potential abuses of power.