In the case of French-Glenn Live Stock Company v. Springer in 1901, the U.S Supreme Court was tasked with determining whether a land grant by Congress to aid in the construction of railroads also included mineral rights. The dispute arose when Springer claimed ownership over certain lands under an agricultural patent issued by the United States, while French-Glenn argued that they had leased these same lands from Central Pacific Railroad Company who received them through a Congressional land grant. The court ruled in favor of Springer, stating that although Congress intended for railroad companies to have access to necessary materials like timber and stone found on granted lands for construction purposes, it did not mean all minerals were included within this provision. Therefore, valuable minerals such as gold or silver remained property of the government until patented separately.

The dissenting opinion in the case of French-Glenn Live Stock Company v. Springer argued that the majority's decision to uphold a lower court ruling, which found in favor of Springer and against French-Glenn Live Stock Company, was incorrect. The dissent contended that the evidence presented did not support this conclusion and instead suggested that French-Glenn had rightful claim to the disputed land based on prior use for grazing livestock. They believed that such usage constituted 'possession' under relevant law, even if no formal title or deed existed. Furthermore, they disagreed with the majority's interpretation of certain statutes related to public lands and their allocation for private use - arguing these were misapplied by both lower courts and now by Supreme Court itself in its affirmation of those rulings. This disagreement extended to how priority should be determined between competing claims: whether it should be based strictly on chronological order (i.e., who claimed first) or also consider other factors like actual usage over time.