In the case of Chappell Chemical and Fertilizer Company v. Sulphur Mines Company in 1898, the U.S Supreme Court ruled on a dispute over sulfur mining rights. The Chappell Chemical and Fertilizer Company had leased land from the Sulphur Mines Company with an agreement to pay royalties based on sulphur extraction. However, when it was discovered that much of the sulphur lay beneath adjacent property not owned by either company, a conflict arose regarding who should bear responsibility for acquiring these additional lands and whether royalty payments should be adjusted accordingly. The court held that under their lease agreement, Chappell was obligated to secure any necessary permissions or properties needed for its operations at its own expense without altering royalty rates agreed upon in their contract with Sulphur Mines Co., thereby ruling in favor of Sulphur Mines Co.

The dissenting opinion in the case of Chappell Chemical and Fertilizer Company v. Sulphur Mines Company argued that the majority's decision to uphold a lower court ruling, which found in favor of Sulphur Mines Company, was incorrect. The dissent believed that there were significant errors made during the trial process which had unfairly prejudiced the jury against Chappell Chemical and Fertilizer Company. Specifically, they took issue with how evidence was presented and interpreted by both parties involved in this dispute over land rights for sulphur mining operations. They felt strongly that these procedural issues should have been enough to warrant a new trial where such mistakes could be avoided or corrected.