In the case of Bedroc Limited, LLC and Western Elite, Inc. v. United States et al., 2003, the U.S Supreme Court was tasked with interpreting a provision in the Pittman Underground Water Act of 1919 that granted certain lands to Nevada "excepting however all minerals." The issue arose when Bedroc Limited and Western Elite began extracting sand and gravel from these lands for commercial use without obtaining permits or paying royalties to the federal government. They argued that 'minerals' as used in this context did not include common substances like sand and gravel. The Supreme Court disagreed with their interpretation, ruling unanimously in favor of the United States. It held that under both ordinary language usage at the time of enactment (1919) and subsequent administrative interpretations by relevant agencies such as Bureau of Land Management (BLM), 'minerals' included substances like sand & gravel which have economic value due to their utility rather than rarity or special characteristic. Therefore, extraction activities carried out by companies required appropriate permissions & payments under existing laws governing mineral rights on public land.

In the dissenting opinion for Bedroc Limited, LLC and Western Elite, Inc. v. United States et al., Justice Stevens argued that the majority's interpretation of "common varieties" in the Mining Act of 1872 was incorrect. He contended that Congress intended to exclude common types of sand and gravel from mining claims because they were not valuable minerals but rather ubiquitous materials used for construction purposes. The majority's decision effectively allowed private companies to claim ownership over these resources on public lands without paying royalties or obtaining permission from federal authorities - a result he believed contradicted congressional intent and undermined public interest in conserving natural resources on federally owned land.