In the 1892 case of Horner v. United States, the U.S. Supreme Court ruled on a matter involving land patents and mining rights in Colorado. The plaintiff, Horner, had purchased land from an individual who had received it via a patent from the federal government under agricultural laws but later discovered that there were valuable mineral deposits on this property. When he attempted to sell these minerals, however, he was sued by another party claiming they held exclusive mining rights due to their own patent granted under different legislation specifically for mineral lands. The court found in favor of Horner stating that once a patent has been issued by the government for any type of land (agricultural or otherwise), it cannot be challenged even if subsequent discoveries reveal that its classification should have been different at time of issuance - such as finding minerals on what was thought to be only suitable for agriculture when patented. This ruling reinforced legal principles regarding finality and certainty in transactions involving public lands; affirming that individuals can rely upon governmental actions without fear those actions will later be invalidated because new information comes to light after-the-fact.

In the dissenting opinion for Horner v. United States, Justice Brewer argued that the majority's decision to uphold a conviction based on an indictment with insufficient evidence was incorrect. He contended that the indictment failed to specify any particular act of fraud committed by Horner and merely accused him of having intent to defraud without providing concrete examples or proof. In his view, this lack of specificity violated Horner's constitutional rights as it did not provide him with adequate information about what he was being charged with in order to prepare a defense effectively. Furthermore, Justice Brewer criticized the majority for allowing hearsay evidence from witnesses who had no direct knowledge of alleged fraudulent acts but only suspicions or beliefs about them. This kind of testimony should have been excluded from trial because it is inherently unreliable and prejudicial against defendants like Horner.