In the Cameron v. United States case of 1913, Ralph H. Cameron, a senator from Arizona and mining entrepreneur, claimed private ownership over land that was part of the Grand Canyon National Monument (now Park). He argued that he had established mining claims before President Theodore Roosevelt declared it a national monument in 1908. The U.S government disputed his claim and sued him for trespassing on federal property. The Supreme Court ruled against Cameron stating that under the Antiquities Act of 1906, which allows presidents to protect areas of historic or scientific interest by designating them as national monuments, all unclaimed lands within those boundaries become public domain regardless if they contain valuable minerals or not. This ruling affirmed the power of the Federal Government to preserve natural resources from commercial exploitation and set an important precedent for future conservation efforts.

In the dissenting opinion for Cameron v. United States, Justice Holmes disagreed with the majority's interpretation of the law and its application to this case. He argued that there was a lack of clear evidence proving that Cameron had intentionally violated federal laws by unlawfully fencing public lands in Arizona. Holmes contended that it was not enough to show that Cameron knew he did not have legal title to these lands; it also needed to be proven beyond reasonable doubt that he knowingly intended to defraud the government by excluding others from using them. The justice further criticized how lower courts handled this case, stating they failed in their duty as triers of fact by accepting circumstantial evidence as proof without considering all possible interpretations or explanations for Cameron's actions. In his view, such an approach undermined fundamental principles of fairness and due process underpinning American criminal jurisprudence.