In the 1896 case of Camfield v. United States, the Supreme Court ruled in favor of the federal government's right to protect public lands from private encroachment or damage. The dispute arose when a landowner named Benjamin Camfield built fences on his property that extended onto federally-owned territory, obstructing access to public lands and water sources. He argued that since he owned land adjacent to these territories, he had rights over them as well. However, the court disagreed with this argument and held that while individuals may own property next to federal lands, they do not have any inherent rights over those public spaces unless explicitly granted by law. This ruling affirmed the power of Congress under Property Clause (Article Four) of U.S Constitution which gives it authority "to dispose of and make all needful Rules and Regulations respecting Territory or other Property belonging to United States." It also set an important precedent for future cases involving conflicts between private interests and conservation efforts on public lands.

In the dissenting opinion for Camfield v. United States, it was argued that the majority's decision to uphold a federal law prohibiting enclosure of public lands infringed upon private property rights. The dissenting justices contended that while Congress has authority over public lands, this power does not extend to regulating privately owned adjacent properties unless they are being used in a manner harmful to the public interest. They believed that there was no evidence presented in this case showing any harm caused by enclosing part of these lands within private boundaries. Furthermore, they asserted that such regulation could lead to an unjust expansion of federal powers at the expense of individual property rights and state sovereignty if left unchecked.