In the case of Great Western Mining and Manufacturing Company v. Harris in 1904, the U.S Supreme Court ruled on a dispute involving land ownership rights. The plaintiff, Great Western Mining and Manufacturing Company, claimed that it had purchased lands from a railroad company which were granted to them by Congress under an act passed in 1866. However, these lands were already occupied by settlers including Harris who argued they had acquired their titles through preemption laws before the grant was made to the railroad company. The court held that while Congress intended for railroads to receive alternate sections of public land along their routes as part of its policy encouraging westward expansion and development; this did not extend to lands previously settled upon or improved prior to such grants being issued. Therefore, those settlers' claims took precedence over any subsequent claim by a railroad or its assignees like Great Western Mining & Manufacturing Co., thus ruling in favor of Harris.

In the dissenting opinion for Great Western Mining and Manufacturing Company v. Harris, it was argued that the court majority erred in its interpretation of Tennessee law regarding mining leases. The dissent contended that under Tennessee law, a lessee who extracts minerals from leased land is required to pay rent based on the value of those minerals at the time they are mined, regardless of whether or not they are subsequently sold or used by the lessee. This obligation exists even if there is no explicit provision in lease agreement stipulating such payment terms. Therefore, according to this view, Great Western Mining should have been held liable for royalties on all coal extracted during their lease period with Harris - irrespective of whether it had been sold or used by them - as per standard practice and understanding within Tennessee's legal framework governing mineral rights and mining leases.