In the case of Andrews v. Swartz in 1894, the U.S Supreme Court ruled on a dispute involving land ownership and mineral rights. The plaintiff, Andrews, claimed that he had purchased land from an individual who was not legally entitled to sell it because they did not own the mineral rights to said property. The defendant, Swartz, argued that he held rightful claim over these resources due to his purchase of them from a third party before Andrew's acquisition of the surface estate. The court ultimately sided with Swartz stating that under Michigan law at this time (where both parties were located), when someone sells or transfers their property without explicitly retaining their mineral rights within the deed itself - those rights are automatically included in what is being sold/transferred unless otherwise stated by law or agreement between parties involved prior to sale/transfer taking place.

In the dissenting opinion for Andrews v. Swartz, it was argued that the majority's decision to uphold a Michigan law prohibiting non-residents from fishing in its waters violated the Privileges and Immunities Clause of Article IV of the U.S. Constitution. The dissenting justices believed that this clause guaranteed citizens of each state equal access to all public facilities and resources across states, including natural ones such as fish in public waters. They contended that while states have rights over their own resources, these rights should not be used to discriminate against out-of-state residents or deny them basic privileges enjoyed by local residents. Therefore, they disagreed with the majority's interpretation which allowed for such discrimination under state laws designed to protect local industries or conserve resources.