In the case of Andrus, Secretary of the Interior v. Idaho et al., 1979, the state of Idaho sued Cecil D. Andrus, then Secretary of the Interior, over a dispute regarding ownership and control over certain forest products on federally owned lands within Idaho's borders. The Supreme Court ruled in favor of Andrus and held that under federal law (the Property Clause), Congress had exclusive authority to determine how resources on federal land were used or disposed off. Therefore, even though some trees may have been planted by state funds as part of fire prevention efforts after World War II, they still belonged to the federal government because they grew on its land. This decision affirmed that states cannot assert proprietary interests or rights against federally-owned property located within their boundaries.

In the dissenting opinion for Andrus, Secretary of the Interior v. Idaho et al., Justice Powell disagreed with the majority's interpretation of Section 7 of the Taylor Grazing Act and its application to this case. He argued that Congress intended to reserve mineral rights in lands patented under this act only when it was explicitly stated in patent documents, not as an automatic provision. Therefore, he believed that Idaho should retain ownership over unclaimed minerals on state land unless expressly reserved by federal law or statute at time of grant. Furthermore, he contended that historical practices supported his view since there had been numerous instances where states were granted full title without reservation clause included in their patents. Thus, according to him, a more accurate reading would be one which respects these past practices and acknowledges congressional intent behind such legislation.