In the case of Dayton Coal and Iron Company v. Barton, 1901, the United States Supreme Court ruled on a dispute involving property rights and mining operations. The plaintiff, Dayton Coal and Iron Company claimed that they had purchased land from Barton with valuable mineral deposits underneath it. However, when they began to mine these minerals, Barton sued them for trespassing as he believed that he still owned the mineral rights to this land despite selling it. The main issue in this case was whether or not the sale of surface land also included subsurface mineral rights if not explicitly stated in the contract. The court ultimately sided with Dayton Coal and Iron Company stating that unless specifically reserved by deed or statute law at time of sale; ownership transfers include both surface and subsurface rights (mineral). Therefore since no such reservation was made during their transaction; Mr.Barton could not claim ownership over said minerals after having sold his property without any reservations.

In the dissenting opinion for Dayton Coal and Iron Company v. Barton, it was argued that the majority's decision to uphold a Tennessee law requiring coal companies to pay miners in legal tender rather than company scrip was unconstitutional. The dissenting justices believed this ruling violated the Contract Clause of the Constitution by interfering with private agreements between employers and employees. They contended that if an employee willingly agreed to be paid in company scrip, then there should be no governmental interference with such contracts. Furthermore, they expressed concern about potential economic consequences of this decision on businesses who relied on these types of payment arrangements due to cash flow issues or other financial constraints.