In the 1911 case of Consumers' Company, Limited v. Hatch, the U.S Supreme Court dealt with a dispute over land ownership and mineral rights in Michigan. The plaintiff, Consumers' Company Limited (a Canadian corporation), claimed that it had purchased property from an individual who had been granted those lands by Congress under an act providing for the sale of Lake Superior Chippewa Indian lands in Michigan. However, this grant did not include mineral rights to copper and iron found on these properties which were reserved for the tribe. The defendant, Hatch argued that he held valid mining leases from tribal representatives allowing him to mine copper and iron on these lands. The court ruled against Consumers' Company stating that while they owned surface rights to their property; subsurface minerals like copper and iron belonged to the tribe as per Congressional Act provisions at time of original land grant. Therefore any lease or agreement made by tribal representatives regarding such minerals was valid even if it conflicted with later private sales agreements concerning surface land use.

In the dissenting opinion for Consumers' Company, Limited v. Hatch, it was argued that the majority's decision failed to properly consider and apply principles of equity. The dissenting justices believed that there were significant questions about whether or not the defendant had acted in good faith when he obtained a lease on land containing valuable mineral deposits from an unsuspecting owner who did not realize their worth. They felt this issue should have been more thoroughly examined before deciding if the defendant could be allowed to profit from his actions at the expense of others. Furthermore, they disagreed with how much weight was given to certain pieces of evidence and testimony during trial proceedings which led them to question if justice had truly been served by upholding lower court rulings in favor of Consumers' Company, Limited.