In the 1918 case of Cleveland-Cliffs Iron Company et al. v. Arctic Iron Company, the U.S Supreme Court dealt with a dispute over iron ore property rights in Minnesota. The plaintiffs, Cleveland-Cliffs Iron Co., and others had purchased certain lands for their valuable iron deposits from the state of Minnesota under an agreement that they would mine these resources within a specified period or forfeit them back to the state. However, before this deadline was reached, another company - Arctic Iron Co., claimed ownership based on federal land patents granted earlier but not recorded until after Cleveland-Cliffs' purchase from the state. The court ruled in favor of Cleveland Cliffs and its co-complainants stating that while both parties had valid claims to title at different times under different laws (state vs federal), priority should be given to those who first developed and utilized these resources as intended by public policy objectives underlying such grants i.e., promoting mining activities rather than mere speculation or holding for future appreciation.

In the dissenting opinion for Cleveland-Cliffs Iron Company v. Arctic Iron Company, it was argued that the majority's decision to uphold a lower court ruling in favor of Cleveland-Cliffs failed to properly consider key aspects of contract law and equity. The dissenting justices believed that Arctic Iron had indeed fulfilled its contractual obligations by making reasonable efforts to secure necessary equipment and labor during wartime conditions, which were beyond their control. They also disagreed with the majority's interpretation of "reasonable time" within the context of contract performance, arguing that such terms should be evaluated based on circumstances surrounding each individual case rather than rigidly defined standards. Furthermore, they contended that even if Arctic Iron did breach its agreement as claimed by Cleveland-Cliffs, any damages awarded should have been limited to actual losses suffered instead of unjust enrichment or speculative profits.