The U.S. Supreme Court case Andrus, Secretary of the Interior v. Utah in 1979 revolved around a dispute over ownership of submerged lands and their mineral rights beneath the Great Salt Lake between the state of Utah and federal government. The State claimed that it had been granted these lands upon its admission to the Union under an equal footing doctrine, while the Federal Government argued they retained control due to provisions within various acts passed by Congress prior to Utah's statehood which reserved all valuable mineral deposits on public land for itself. The court ruled in favor of the federal government, stating that at no point did Congress explicitly relinquish control over these specific lands or minerals therein when admitting new states into Union; therefore, they remained property of United States.

In the dissenting opinion for Andrus v. Utah, Justice William Rehnquist disagreed with the majority's interpretation of the Mining Act of 1872. He argued that Congress intended to grant states ownership rights over minerals found on their lands when it passed this legislation. According to him, by ruling in favor of federal ownership, the Court was effectively rewriting history and ignoring clear legislative intent. Furthermore, he contended that previous court decisions had upheld state mineral rights under similar circumstances and should have been considered as precedents in this case. Therefore, he believed that Utah should retain control over its natural resources rather than being forced to cede them to federal authorities.