In the case of Angle v. Chicago, St. Paul, Minneapolis and Omaha Railway Company in 1893, the U.S Supreme Court ruled on a dispute involving land rights between a private individual and a railway company. The plaintiff, Mr. Angle had purchased land from the federal government under an act that granted lands to Wisconsin for railroad purposes but reserved mineral rights to the United States. After discovering iron ore on his property he sought to mine it but was prevented by the defendant railway company who claimed they owned these mining rights as part of their original grant from Wisconsin which included "all necessary grounds" for building and operating their rail line. The court held that while Congress intended to reserve all minerals beneath such lands when granting them away, this did not include iron ore because at that time (1856) it wasn't considered valuable or useful due its difficulty in extraction with existing technology; hence could not be classified as 'mineral'. Therefore Mr.Angle's purchase would have included any iron deposits present since they were not specifically excluded by Congress' reservation clause. This ruling established important precedent regarding interpretation of Congressional intent in land grants and clarified what substances are considered 'minerals' within legal context.

In the dissenting opinion for Angle v. Chicago, St. Paul, Minneapolis and Omaha Railway Company, Justice Brewer argued that the majority's decision was inconsistent with previous rulings of the court regarding eminent domain laws. He contended that a private corporation should not be allowed to take land from an individual without just compensation under any circumstances, even if it is in service of public use like building a railway line. The justice believed this ruling violated property rights protected by both state and federal constitutions. Furthermore, he disagreed with the majority's interpretation of 'public use,' arguing that it should only apply when there is direct benefit to general public rather than indirect benefits such as economic development or job creation which were cited in this case.