In the 1903 case of Holden v. Stratton, the U.S Supreme Court dealt with a dispute over mining rights in Colorado. The plaintiff, Holden, claimed that he had acquired ownership of certain mineral veins through his purchase of surface land from Stratton. However, Stratton argued that these veins were not included in the sale as they extended beyond the boundaries described in their agreement and into adjacent property owned by him (Stratton). The court ruled against Holden's claim stating that under federal law governing mining claims (the Mining Act), miners only have exclusive right to mine minerals within their vertical planes extending downward but do not own any part of a vein which extends outside those boundaries even if it originates within them. Therefore, since some parts of these veins lay beneath Stratton’s adjacent property and extended outside Holden's purchased area vertically downwards; they remained under Stratton’s ownership.

In the dissenting opinion for Holden v. Stratton, Justice Harlan argued that the majority's decision was a misinterpretation of both the Constitution and previous court rulings. He contended that it was not within Congress' power to regulate labor contracts between private individuals in individual states, as this fell under state jurisdiction rather than federal. Furthermore, he disagreed with the majority's view that such regulation could be justified by its indirect effect on interstate commerce. In his view, accepting this argument would allow Congress to control almost any aspect of life under the guise of regulating commerce. Finally, he warned against expanding federal powers at the expense of state rights and individual liberties.