In the case of Bowling and Miami Investment Company v. United States in 1913, the Supreme Court dealt with a dispute over land ownership in Florida. The plaintiffs, Bowling and Miami Investment Company, claimed that they had purchased lands from the state of Florida which were swampy and unfit for cultivation or habitation. However, these lands were later discovered to contain valuable phosphate deposits. The U.S government contested their claim stating that under an Act passed by Congress in 1849 granting swamp lands to states for reclamation purposes did not include mineral-rich subsoil rights; hence it retained ownership of any minerals found beneath such granted land's surface. The Supreme Court ruled against Bowling and Miami Investment Company affirming that when transferring swampland titles to states under the Swamp Land Act of 1850, federal law did not convey subsurface mineral rights unless explicitly stated otherwise within legislation or agreements at time of transfer. Therefore, despite owning surface rights through purchase from Florida State who received them via this act originally - all underground resources remained property belonging exclusively towards United States Government due its retention on those specific entitlements during initial allocation process.

In the dissenting opinion for Bowling and Miami Investment Company v. United States, Justice Holmes disagreed with the majority's decision to uphold a lower court ruling that allowed the government to seize land owned by private individuals under eminent domain laws. He argued that while it was within the government's rights to take property for public use, they should not be able to do so without just compensation. In this case, he believed that fair market value had not been given for the seized properties. Furthermore, he contended that there were other ways in which these lands could have been used or acquired by negotiation rather than seizure. The justice also expressed concern about potential abuse of power if such seizures were permitted without adequate checks and balances in place.