In the case of Benson Mining and Smelting Company v. Alta Mining and Smelting Company, 1891, the Supreme Court ruled on a dispute over mining rights in Utah. The Benson company claimed that they had been unlawfully ousted from their mining claim by the Alta company and sought to recover damages for ore removed from their property. However, it was found that both companies were operating under valid patents issued by the United States government which overlapped due to an error in surveying boundaries during patent issuance. The court held that when two mineral land patents issued by the U.S Government overlap, neither party can oust another based solely on priority of patent date as this would be unjust enrichment; instead each party is entitled to mine ores beneath its own surface area only up until reaching a vertical plane where both claims intersect or overlap underground (apex law). Therefore, any minerals extracted beyond this point must be returned or compensated for accordingly.

In the dissenting opinion for Benson Mining and Smelting Company v. Alta Mining and Smelting Company, Justice Field disagreed with the majority's view that a patent could be invalidated due to an insufficient description of the invention in question. He argued that while it is important for inventors to provide clear descriptions of their inventions, this requirement should not be used as a means to invalidate patents where there is no evidence of fraud or deception on part of the inventor. In his view, if an invention has been described sufficiently enough for someone skilled in relevant art or science to understand its nature and operation without undue experimentation then such description should suffice irrespective of whether every detail was included or not. Furthermore, he believed that any ambiguities regarding interpretation should favor patentee rather than those seeking invalidation because they are ones who took risk by disclosing their innovation publicly through patent system instead keeping it secret.