In the case of Chadwick v. Kelly in 1902, the United States Supreme Court ruled on a dispute involving land ownership and mineral rights. The plaintiff, Chadwick, claimed that he had purchased land from an individual who was not legally entitled to sell it because they did not own the mineral rights to the property. The defendant, Kelly, argued that he held rightful claim over these resources due to his purchase of them from a third party prior to Chadwick's acquisition of surface rights. The court ultimately sided with Kelly stating that while both parties had legitimate claims under their respective purchases; however, since minerals were considered part of real estate at common law and there was no explicit reservation or exception made when transferring title for surface rights only - thus making any subsequent sale void as against previous grantee (Kelly) who bought entire interest including minerals.

In the dissenting opinion for Chadwick v. Kelly, it was argued that the majority's decision to uphold a state law requiring railroad companies to provide separate but equal accommodations for white and black passengers violated both the Fourteenth Amendment and principles of interstate commerce. The dissent contended that this law imposed an undue burden on interstate commerce by forcing railroads to rearrange their cars at every state line in order to comply with differing segregation laws. Furthermore, they asserted that such racial segregation inherently constituted unequal treatment under the law, thereby violating individuals' rights under the Equal Protection Clause of the Fourteenth Amendment. They maintained that any legislation mandating racial separation is fundamentally discriminatory and therefore unconstitutional.